Privacy Notice

Shared Wealth International Limited (“SWI”, “we”, “us”, “our”), trading as Shared Wealth Technology (a brand division of Shared Wealth International Ltd), operates the SWT Asset Management platform at assets.sharedwealth.technology (the “Platform”).

This Privacy Notice explains how we collect, use, store, and share personal data in connection with the Platform and related business activities. It is intended for UK GDPR / Data Protection Act 2018 compliance and is provided for legal review.

Effective date: 3 August 2026
Version: 1.0.0

1. Who we are

Shared Wealth International Ltd is a private limited company registered in England and Wales.

2. Contact details

Data Protection Officer: Cliff Southcombe
Email: privacy@sharedwealth.international

Shared Wealth International Ltd
Falconhurst Mount Pleasant South Robin Hoods Bay Whitby England YO22 4RQ

Questions about this notice, data subject rights, or complaints about our handling of personal data: privacy@sharedwealth.international or use our complaints form.

3. Scope

This notice applies to personal data we process about:

• Internal staff and contractors of Shared Wealth group entities
• Portfolio company users (founders, finance, operators, directors)
• Investors and prospective investors granted Platform access
• Business contacts, suppliers, and website visitors
• Anyone who submits a contact, access, or privacy request

4. Personal data we collect

Depending on your relationship with us, we may process:

• Identity and contact details (name, email, phone, organisation, role)
• Account and authentication data (credentials hashes, MFA status, session metadata, IP, device)
• Organisation, portfolio, investor, governance, and capital-structure information you enter
• Documents and files you upload (including encrypted document vault content)
• CRM, engagement, and communication records
• Usage, audit, and security logs
• Cookie / consent preferences
• AI chat prompts and outputs where you use Platform AI features
• Support and complaint correspondence

We do not intentionally collect special category data unless you choose to provide it in documents you upload. Where that occurs, we rely on an appropriate UK GDPR condition and restrict access.

5. How we collect data

• Directly from you (registration, forms, uploads, chat, email)
• From authorised administrators in your organisation
• From connected services you enable (e.g. Google Drive / Workspace, email integrations)
• From publicly available company sources (e.g. Companies House) when you run research features
• Automatically via essential cookies, security logs, and (with consent) analytics

6. Purposes and lawful bases

7. Sharing and sub-processors

We share personal data with sub-processors listed at /subprocessors, including hosting, storage, email, and AI providers. We do not sell personal data.

We may also share data with professional advisers, insurers, regulators, or law enforcement where required, and with other Shared Wealth group entities where needed to operate the Platform under appropriate safeguards.

8. International transfers

We primarily host in the UK / EU. Where a provider processes data outside the UK/EEA, we use appropriate safeguards (UK IDTA, SCCs with UK Addendum, or adequacy).

9. Retention

We keep personal data only as long as needed for the purposes above, including legal, accounting, and dispute purposes. Account data is retained for the life of the account plus a reasonable wind-down period after closure unless a shorter deletion is required or requested and lawful. Audit logs are retained per our security policy (typically 12 months unless a longer period is required).

10. Security

We apply technical and organisational measures including TLS in transit, encryption at rest for sensitive documents, role-based access, CSRF protection, rate limiting, and audit logging. See /security for a high-level overview.

11. Your rights

You may have the right to access, rectify, erase, restrict, object, port data, and withdraw consent. Contact privacy@sharedwealth.international or use /complaints. We will respond within one month (UK GDPR).

You may also complain to the Information Commissioner’s Office.

12. Automated decision-making

We do not make solely automated decisions with legal or similarly significant effects about individuals. AI features assist users; humans remain responsible for reliance on outputs. See /ai-disclosure.

13. Children

The Platform is for business users aged 18+. We do not knowingly create accounts for children.

14. Changes

We may update this notice. Material changes will be published here with a new effective date. Continued use after the effective date constitutes notice of the update; logged-in users may be asked to re-acknowledge where required.

See also our Cookie Policy and Terms of Service.