Information
Collection

The Information We Collect

To deliver our services effectively and maintain accurate client records, we may collect and retain personal data for the following purposes:

• Providing, managing, and improving our products and services
• Establishing and maintaining client relationships and accounts
• Meeting legal, regulatory, and compliance obligations
• Communicating with you about products, updates, and relevant service information

The personal data we collect may include, but is not limited to:

• Full name, residential or postal address, email address, and contact number
• Date of birth and proof of identity documents
• Employment, occupation, and professional background
• Banking and payment details
• Financial information relevant to your investment objectives
• Tax identification details

Information is generally obtained directly from you — via forms, consultations, calls, or secure digital interactions — or through authorised third parties such as your accountant, adviser, or product provider. In certain cases, we may also source information from publicly available databases where lawful to do so.

We will only collect special category data (such as health information required for insurance or protection products) with your explicit consent or when another legal basis under the EU GDPR applies.

Data
Usage

How We Use and Manage Your Data

Your personal data is used strictly for legitimate business and compliance purposes, including to:

• Deliver financial advice and manage your investments effectively
• Set up, maintain, and monitor your accounts and portfolios
• Carry out transactions and instructions accurately and securely
• Administer transfers, payments, and associated benefits
• Provide performance reports and respond to service enquiries
• Send updates, regulatory notices, and — with your consent — relevant marketing communications

Legal basis for processing: we rely on several lawful grounds as defined by the EU GDPR, including the performance of a contract, compliance with legal or regulatory obligations, legitimate business interests (such as improving our services and ensuring operational efficiency), and, where required, your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Information
Disclosure

Who We Share Your Information With

We may share your personal data with carefully selected third parties who assist us in delivering our services or meeting our legal and regulatory obligations. These may include:

• Service providers engaged to support our operations, such as administrators, custodians, insurers, investment managers, IT, and mailing providers
• Authorised banks and financial institutions involved in client transactions
• Professional advisers appointed by you or by Mulberry Wealth Securities where appropriate
• Referring or introducing partners who facilitate access to our services
• Regulators, government bodies, and law enforcement agencies when required by law or regulation
• Scheme employers, trustees, or pension administrators where applicable
• Personal representatives or beneficiaries, in cases involving estates or relevant legal matters

When personal data is transferred across borders, we ensure that an equivalent level of protection is maintained through recognised safeguards, such as the EU Standard Contractual Clauses or other legally approved mechanisms compliant with applicable data protection laws.

Access and
Amendment

Your Rights to Access and Update Information

Under the EU GDPR, you have a number of rights in relation to your personal data. These include the right to request access, correction, deletion, restriction of processing, portability of your data, and to object to certain uses. You may also have rights regarding automated decision-making and profiling, where applicable.

We are committed to maintaining accurate and up-to-date records. If you believe any of your details are incorrect or incomplete, please contact us and we will promptly make the necessary amendments.

To exercise your rights or to make a privacy-related request, please contact our Privacy Officer at [email protected].

Feedback and
Complaints

Raising a Concern About Privacy

If you have questions or concerns about how your personal data is handled, please contact our Privacy Officer at [email protected]. We will acknowledge and respond to your concern within 30 days wherever possible.

Data
Protection

How We Keep Your Information Secure

We implement a comprehensive range of technical and organisational safeguards to protect your personal data from unauthorised access, alteration, disclosure, or loss. These include secure systems, encryption where appropriate, restricted access controls, staff training, and regular monitoring of our service providers.

Although we take every reasonable precaution to secure your data, please be aware that transmission of information over the internet involves inherent risks. We recommend exercising care when deciding how and when to share personal information with us online.