Privacy policy

This privacy policWhen we say “we”, “us”, or “Nucleus” in this policy we mean all the companies that make up Nucleus. They are:

• Nucleus Financial Group Limited (registered office: Elder House St Georges Business Park, 207 Brooklands Road, Weybridge, Surrey, England, KT13 0TS)
• Nucleus Financial Service Limited (registered office: Elder House St Georges Business Park, 207 Brooklands Road, Weybridge, Surrey, England, KT13 0TS)

Nucleus is the controller for the personal information we process, unless otherwise stated.

Our postal and email address are:

Chief Risk Officer
Nucleus Financial Group
Nucleus HQ, Greenside
12 Blenheim Place
Edinburgh
EH7 5JH

Email: dataprotection@nucleusfinancial.com

In general terms, we collect and use personal information about you to:

• Deliver our services and meet our legal responsibilities
• Verify your identity where this is required
• Contact you, where we are allowed, by post email or telephone about important changes to our Website, products or services
  
• Maintain our records
• Process financial transactions
• Prevent and detect crime, fraud or corruption

This includes:

• Your personal contact details (such as name, date of birth and email/postal address);
  
• Documentation confirming your identity, tax residency and legal authority;
• Information connected to the product or services you use (for example, bank account details);
• Information you provide about other people (for example, for joint applicants or beneficiaries for products or services);
  
• Your correspondence with us (such as letters, emails, calls or meetings);
• Images of you collected by photography or security cameras should you visit our office or one of our events;
• Information collected automatically via cookies when you visit one of our websites;
• Information relating to your health, marital or civil partnership status (only where it is necessary to provide the product or service you have requested or if required to comply with our legal obligations)

Whenever we process your personal information, we must have something called a “legal basis” for what we do. The different legal bases we rely on are:

• Consent: you have told us you are happy for us to use your personal information for specific purpose(s)
• Legitimate interest: the use of the information is necessary for us to conduct our business, but not where our interests are overridden by your interests or rights.
• Performance of a contract: we must use your information to be able to provide you with one of our products or services.
  
• Legal obligation: we are required to use your information by law.

The exact nature of the processing will depend on your relationship with us. These are explained further in the next sections

If you are a financial adviser and use our services and products we may collect personal information directly from you and your employees because of the contractual relationship in place between us.

To provide our services to you,we require to process personal information about you and if you do not wish for your personal information to be processed then we will be unable to provide you with our services.

As set out in our terms of business, information relating to your clients is shared between us and you on a data controller to data controller basis. You should read our terms of business carefully to understand your responsibilities in relation to such sharing of personal information.

In addition to information that you provide to us, we may also obtain information about you fromregulatory authorities and credit reference agencies.

Reason for processing your personal information

• Make a decision about your application to use the platform and check you are eligible to use the platform services on an ongoing basis
• Contact you
• Administer our terms of business with you and exercise our rights
• Process corporate actions in relation to client investments
• Ensure compliance with the terms of our contract
• Provide and process payments of adviser charge
• Business management and planning, including accounting or auditing
• Monitor your use of our IT and communications systems
• Marketing and training
• For the establishment, exercise, or defence of legal claims
• To keep you up to date with the products and services that we offer to you and your clients

Letting you know about our other products and services

We might use your information to let you know about other products and services that we offer which may be of interest to you and we may contact you by post, telephone and by e-mail.

You can change your marketing preferences at any time by updating your email preferences which can be found in the footer of every email we send you.

Where you have contracted for our services, we may process personal information about you (or the persons you are applying on behalf of) in order to facilitate the contractual relationship in place between us and to provide our services.

To provide our services in an effective and efficient way, we require to process personal information about you or the person you are applying on behalf of. This information may come from you directly, from the financial adviser you have instructed to act on your behalf and credit reference agencies.

This information is necessary to enable us to provide the services and if you do not wish for this personal information to be processed when we will be unable to provide you with our services.

Most of the personal information we process is provided to us directly by you via your financial adviser for one of the following reasons.

Reason for processing your personal information

• Make a decision about your application to open an account, product and/or use the platform services
• Make decisions about your continued access to the platform or services on an on-going basis and make arrangements for the termination of our contract if appropriate
• Contact you
• Administer our contract with you and exercise our rights
• Ensure compliance with our terms and conditions
• Process payments and deducting charges
• If applicable, deduct tax
• Business management and planning, including accounting or auditing
• Making improvements to our products and services
• Monitor your use of our IT and communications systems
• To comply with our legal, regulatory, and corporate governance obligations
• For the establishment, exercise, or defence of legal claims
• To ensure our policies such as those concerning security, fair use and data security are adhered to
• To ensure our testing plans adequately reflect real world usage of the systems
  

Letting you know about our other products and services

We do not market directly to you. Instead, we provide information to financial advisers to help them to keep their clients up to date with the products and services. Any marketing that you receive for our products and services will be the responsibility of your financial adviser. For further information about this, including how to change your preferences, please contact your financial adviser or check their privacy statement.

To ensure that we are providing an efficient and effective service we will sometimes be required to share the information we have collected with third parties that support us in providing this service. These third parties are::

• Your financial adviser
• Companies we have chosen to support us in the delivery of our products and services, for example, IT service providers, consultants and companies that provide administrative services
• HM Revenue & Customs, regulators and other authorities
  
• Companies you ask us to share data with
• Credit reference agencies to carry out anti-money laundering or identity verification checks
• RL 360 Limited (if you invest in the Nuclues offshore bond)
• Sanlam Life & Pensions UK Limited (if you invest in the Nucleus onshore bond). Sanlam privacy statement (PDF).
• Scottish Friendly Life Assurance Society Limited (if you have invested in the Scottish Friendly onshore bond or Nucleus APP Pension Account)
• Pension fund trustees (if you invest in a SIPP)
• Fund managers (or their appointed representatives) of the relevant fund(s) you have invested in
• Discretionary fund managers, should you elect to use such a service
• Banks with which we operate client banking arrangements.

We may have to share your data with other companies in the Nucleus group, for example we will share your personal information with other entities in the Nucleus group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

Most of your information is processed in the UK and European Economic Area (EEA). We may process some of your information outside the EEA, including countries such as the United States and India. Where your information is processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK or EEA data privacy laws. We will put in place appropriate contracts with our third party suppliers and take steps to check these suppliers are fulfilling their obligations.

Whenever we share your personal information, we will do so in line with our obligations to keep your information secure.

You can find out more about the bodies we share your information with by contacting dataprotection@nucleusfinancial.com.

When you visit our website or use other online services we may automatically collect information about your usage of our websites and our online services using cookies. To find out more about how we use cookies please see our cookie policy.

The right to access

You have a right to request that we provide you with a copy of the personal information that we hold on you. You also have the right to be informed of (a) the source of your personal information; (b) the purposes, legal bases, and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities your personal information may be transferred to.

The right to rectification

You have the right to request that we rectify any inaccurate personal information. We may verify the accuracy of the personal information before rectifying it.

The right to erasure

You can request that we delete your personal information, but only where

• it is no longer required for the purposes for which it was collected.
• you have withdrawn your consent (where the processing is based on consent)
• following a successful right to object (see below)
• it has been processed unlawfully
• to comply with a legal obligation to which you are subject.

We are not required to delete your information where the processing is necessary

• for compliance with a legal obligation
• for the establishment, exercise or defence of legal claims.

The right to erasure

We are not required to delete your information where the processing is necessary

• for compliance with a legal obligation
• for the establishment, exercise or defence of legal claims.

The right to restrict the processing

You can request that we restrict your personal information, but only

• where its accuracy is being contested, to allow us to verify its accuracy
• the processing is unlawful, but you do not want it deleted
• it is no longer needed for the purposes for which it was collected, but we need it to establish, exercise, or defend a legal claim
• you have exercised your right to object, and we are verifying our legitimate interests.

The right to object

You can object to any processing where we process under legitimate interest, providing you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we will need to demonstrate we have compelling interests to continue to process your information.

The right to portability

You have the right to ask us to provide you with an electronic file containing all your personal information we hold about you.

Rights regarding automated decision making

We use automated decision making, including profiling, in certain circumstances, such as when it is in out legitimate interest to do so, or where we have a right to do so because it is necessary for us to enter into, and perform, a contract with you.

You have the right not to be subject to a decision based solely on automate processing, including profiling, which has a legal impact on you.

Please contact us in any of the ways set out in the Contact information and further advice section if you wish to exercise any of these rights.

We ask that you please attempt to resolve any complaints about how we handle personal information with us first, but you also have the right to lodge a complaintwith the Information Commissioner’s Office:

Online: https://ico.org.uk/make-a-complaint/

By phone: 0303 123 1113

By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

We keep this privacy policy under regular review and will place any updates on this website. Paper copies of the privacy policy may also be obtained by emailing dataprotection@nucleusfinancial.com.

This privacy policy was last updated on 21 December 2021.