Privacy Policy

Who we are

Wealth Spectrum ("Wealth Spectrum", "we", "us", or "our") is a mobile application operated by Threewords Capital that helps you view, organise, and understand your financial and investment information. In this policy the words "app", "service", and "platform" all refer to the Wealth Spectrum application and the features within it.

Threewords Capital is the controller responsible for your personal information as described in this policy. If you have questions, you can reach us using the details in the Contact us section.

1. Information we collect

Information you provide to us

• Account details such as your name, email address, and phone number.
• Profile and preference settings you choose within the app.
• Financial and portfolio information that you enter or connect, such as holdings, transactions, and goals.
• Messages, feedback, and support requests you send to us.

Information we collect automatically

• Device information, including device model, operating system version, unique device identifiers, and app version.
• Usage information, such as the features you use, screens you view, and the dates and times of your activity.
• Diagnostic information, including crash reports and performance data that help us keep the app stable.
• General location derived from your IP address. We do not collect precise GPS location unless you grant permission for a feature that needs it.

Information from third parties

If you choose to connect an external account or use a sign in provider, we receive the information you authorise that provider to share, such as your name, email address, or account balances. We only request what a feature needs to work.

2. How we use your information

We use the information described above to:

• Create and manage your account and provide the app's features.
• Display, organise, and analyse the financial information you choose to add.
• Personalise your experience and remember your settings.
• Send you service messages, security alerts, and, where you have agreed, updates about features.
• Monitor, troubleshoot, and improve the performance, safety, and reliability of the app.
• Detect, prevent, and respond to fraud, abuse, and security incidents.
• Meet our legal, regulatory, and tax obligations.

We do not sell your personal information, and we do not use your financial data for advertising.

3. Legal bases for processing

Where data protection laws such as the GDPR apply, we rely on one or more of the following legal bases to process your information:

• Contract: to provide the service you have signed up for.
• Consent: for optional features and communications, which you can withdraw at any time.
• Legitimate interests: to secure, maintain, and improve the app in ways you would reasonably expect.
• Legal obligation: to comply with laws that apply to us.

4. Device permissions

The app may ask for certain device permissions. Each one is optional and is only used for the feature it supports. You can change these at any time in your device settings.

• Camera: to scan documents or codes, or to set a profile photo.
• Photos and files: to upload statements or images you choose.
• Notifications: to send alerts and reminders you have enabled.
• Biometrics (Face ID or fingerprint): handled entirely by your device to unlock the app. We never receive your biometric data.
• Location: only if you enable a feature that needs it, and only at the level that feature requires.

5. How we share information

We share personal information only in the following circumstances:

• Service providers: trusted companies that host our infrastructure, deliver notifications, or provide analytics and support on our behalf, bound by contracts that require them to protect your data.
• At your direction: when you connect an account or ask us to share data with a party you choose.
• Legal and safety: when required by law, regulation, legal process, or to protect the rights, property, and safety of our users and the public.
• Business transfers: in connection with a merger, acquisition, or sale of assets, with notice to you where required.

6. Third party services

We use a small number of third party services to run the app, which may include cloud hosting, crash reporting, and product analytics. These providers process data on our behalf under agreements that limit how they may use it. The current list of providers is available on request using the details in the Contact us section.

The app is not affiliated with Apple or Google. The App Store and Google Play distribute the app but do not control this policy.

7. Data retention

We keep your personal information for as long as your account is active or as needed to provide the service. After that, we retain information only for the period required to meet legal, accounting, or reporting obligations, to resolve disputes, and to enforce our agreements. When information is no longer needed, we delete it or make it anonymous.

8. How we protect your data

We use technical and organisational measures designed to protect your information, including encryption in transit, access controls, and regular security reviews. No method of transmission or storage is completely secure, so we cannot guarantee absolute security, but we work to protect your information and to respond promptly to any incident.

9. Your rights and choices

Depending on where you live, you may have some or all of the following rights over your personal information:

• Access a copy of the information we hold about you.
• Correct information that is inaccurate or incomplete.
• Delete your information, subject to legal limits.
• Object to or restrict certain processing.
• Request a portable copy of information you provided to us.
• Withdraw consent at any time, without affecting processing done before withdrawal.

You can exercise most of these rights inside the app, or by contacting us. We will respond within the timeframe required by law. If you are in the European Economic Area or the United Kingdom, you also have the right to complain to your local data protection authority. If you are a California resident, you have the right to know what personal information we collect and to request its deletion, and we will not discriminate against you for exercising these rights.

Deleting your account

You can request deletion of your account and associated personal data at any time from within the app, or by emailing us. We will confirm once your data has been removed, apart from anything we are legally required to keep.

10. Children's privacy

The app is intended for adults and is not directed to children under the age of 16. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will delete it.

11. International data transfers

We may process and store your information in countries other than the one where you live. When we transfer information across borders, we use safeguards required by law, such as standard contractual clauses, to make sure your information stays protected.

12. Changes to this policy

We may update this policy from time to time. When we make material changes, we will update the effective date at the top and, where appropriate, notify you within the app. We encourage you to review this page periodically.

13. Contact us

If you have questions about this policy or how we handle your information, please contact:

• Threewords Capital, for Wealth Spectrum
• Email: privacy@threewordscapital.com
• Address: [Registered address]