Nutmeg may change this policy from time to time by updating this page. We will inform you of any material changes we make to this policy to ensure you are satisfied with our approach to managing your personal data.
- What information we collect and why
We gather your personal data for the following purposes, and we will only use it for the purpose it was collected.
1.1 Opening an account and suitability assessment
In order to create an account with Nutmeg we need to collect some personal information which allows us to verify your identity, assess your tolerance to investment risk as part of our regulatory obligations to determine the suitability of our products for you, and is necessary for the performance of the Agreement. You may provide us with this information as part of the account opening process through our website or directly to a Client Support agent.
1.2 Operating your account
On a day-to-day basis we process information necessary for your account to function correctly and for us to perform our contractual obligations toward you, this can range from details required for us to trade your investments, to data necessary for our technology infrastructure to run. This information is usually generated automatically by your account and our systems or may be collected as a result of a fault you have reported to our Client Support Team.
1.3 Providing you with information and support
We record all interactions with our Customer Support Team including, but not limited to, emails, phone calls and our Secure Nutmails. We will also generate and keep a record of any mandatory or ad hoc statements and reports we produce for you.
1.4 Improving our services and products
We are always looking to improve our services to you and our product offering, and for this reason we will collect and process data (including profiling) about how you interact with our website, such as where you click and your IP address, for analytical, development and research purposes. We may also receive information relating to you form third-party analytics providers. This helps improve our current services and may inform how we develop new products and services.
We may use your personal data to share marketing information with you including direct marketing (we will always seek your consent in accordance with the relevant legal and regulatory requirements prior to engaging in this type of processing). You can unsubscribe from marketing communication by clicking the link provided in relevant emails, or through the dedicated Preference Centre in your dashboard. You have a right to opt out of this type of processing, including profiling for direct marketing purposes, and can do so by contacting us at email@example.com.
1.6 Showing you an interest-based web journey
We may employ common tracking technology such as cookies and pixels to understand how you interact with our website for the purpose of showing you content on it that we think is most relevant to you.
You have a right to opt out of this type of processing, including profiling for direct marketing purposes, and can do so by contacting us at firstname.lastname@example.org.
1.7 Complying with legal and regulatory obligations
We collect as well as receive information about you from third parties such as details necessary to verify your identity to comply with legal and regulatory requirements for the prevention of financial crime. When required for the provision of the services, or volunteered by you, we may also process information which is classed as ‘special category’ under the GDPR including, but not limited to, information about your health and personal circumstances in order to service you in line with the FCA vulnerable customers guidelines and principles (we will always seek your consent in accordance with the relevant legal and regulatory requirements prior to engaging in this type of processing).
- Why we need to collect this information
Nutmeg is required, in accordance with the General Data Protection Regulation - Regulation EU 2016/679 ("GDPR") to have a purpose and a legal basis for processing your personal data.
We collect this information primarily to satisfy legal requirements and to enable us to provide the services required under the Agreement between you and Nutmeg.
In particular, in order to provide you with a recommended portfolio and risk profile for your investment we are required to collect responses to the risk questionnaire and anticipated time horizon mentioned above. In some cases, your responses may result in our system determining that our investment product is not suitable for you. If you are not satisfied with the result of this process, you may contact us at email@example.com or by telephone on (0203) 598 1515. We can provide you with additional information about how we reached this decision and your options.
In order to comply with our obligation to treat customers fairly under the FCA’s principles, it may be necessary for us to record certain personal data about a sub-set of our customers who may be classed as vulnerable customers under these principles. Some of this data may be classified as special category data, for which we require explicit consent, including information about a customer's mental and physical health. This data will be stored securely and accessed only by appropriately authorised personnel. The data will not be transferred to, or processed by, third parties.
Where explicit consent is required, we will seek this from you, for example with respect to marketing preferences. However, in most cases explicit consent is not required, and implicit consent is inferred such that we may perform our responsibilities under the Agreement. Where explicit consent is required and not provided or withdrawn it may result in non-benefit of service, or the inability to open an account with Nutmeg.
- Lawful basis for processing
To process your personal data, we will rely on a number of different legal bases depending on the purpose of the processing, such as where:
- We have a legal or regulatory obligation to process your personal data, such as performing checks for the prevention of financial crime.
- We need to process your personal data in order to perform the Agreement between you and us;
- We have a legitimate business interest to process your personal data which is not overridden, or unbalanced compared to your interests and/or fundamental rights and freedoms;
- You have given us your consent to send you marketing information or to process special category data relating to you, such as health information.
- Direct Marketing
Nutmeg will only send you marketing communications where you have given us your explicit consent. This can be managed through our preference centre where you may withdraw this consent at any time. If you have any questions please contact firstname.lastname@example.org.
- Your rights
5.1 The right to be informed
5.2 The right of access and data portability
You have the right to access the data that Nutmeg holds on you and request a portable version of this data.
5.3 The right to rectification
You have the right to have inaccurate personal data rectified, or incomplete data completed respectively.
5.4 The right to erasure (“the right to be forgotten”)
You have the right to request erasure of the data held by Nutmeg. Nutmeg is required to balance this right with its obligations under law and regulation with respect to record retention.
5.5 The right to object
You have the right object to the processing of your personal data when this is based on legitimate interest, including profiling. You also have the right to object to the processing of your personal data for marketing purposes, including profiling for direct marketing purposes.
5.6 The right to restrict processing
You have a right to request Nutmeg to restrict the processing of your personal data, for instance while process other requests under your rights as a data subject such as the right to object and the right to rectification detailed above.
5.7 Rights in relation to automated decision making and profiling
Where it is not necessary for the performance of the contract, or based on your explicit consent, you have the right not to be subject to a decision based solely on automated decision-making and profiling.
Should you have any complaints about how we process your personal data you can get in contact by emailing us at email@example.com. You also have the right to complain to the relevant member state authority, which for the United Kingdom is the Information Commissioner’s Office, by visiting their website or calling their helpline on 0303 123 1113.
You may seek to exercise any of these rights by emailing us at firstname.lastname@example.org.
- Data Retention
Nutmeg is required to retain certain data records to comply with the Financial Conduct Authority’s (FCA) general recording keeping requirements. To comply with these requirements, Nutmeg’s policy is to retain this data for 7 years, and for any additional period required under prevailing regulation.
Your personal information may be transferred or disclosed to third parties where necessary under the Agreement. This enables us to provide Services to you and to discharge our obligations to third parties, including relevant government agencies and regulators. Such third parties may also have their own data retention periods.
In particular, we use GoCardless to process your Direct Debit payments. More information on how GoCardless processes your personal data and your data protection rights, including your right to object, is available at www.gocardless.com/privacy/.
We use Stripe to process debit card payments. More information on how Stripe processes your personal data and your data protection rights, including your right to object, is available at www.stripe.com/gb/privacy.
Any requests of Nutmeg for erasure during the retention period may not apply to all of these data records, and such records may only be deleted once the retention period has expired.
- With whom do we share this information
For the purposes of the Agreement we are required to share your information with third parties, the situations in which we share this information are detailed below:
- Regulatory bodies or the police to comply with our legal obligations;
- Fraud prevention agencies, and other organisations in order to detect and prevent financial and other crime;
- Suppliers, where necessary for the performance of the contract.
We may also share your personal information with certain suppliers when we have a legitimate interest to do so, or your explicit consent, as detailed below:
- Data, service and software providers to help improve, develop and maintain our products and website (which may include, for example customer data modelling or statistical and trend analysis);
- Data, service and software providers to provide you with an interest-based web journey.
We will endeavour to anonymise your data and/or minimise the amount of your data we share with these third parties, where possible. Prior to sharing any of your personal information with these suppliers we will ensure the appropriate contractual, technical and organisational measures are in place to safeguard your personal information, including the relevant arrangements should we transfer this data outside of the EEA.
We will not sell or lease your personal information to third parties unless we have your permission to do so.
- Data Controller vs Data Processor
Under the GDPR, a Data Controller is the entity that determines the purposes, conditions and means of the processing of personal data.
The Data Processor is the entity that processes data on behalf of the Data Controller.
Nutmeg is the Data Controller of your personal information and as noted above we employ the services of a number of third parties to provide the service under the Agreement and to improve our product and services. Customers personal data is shared where appropriate with third parties that are Data Processors or Data Controllers in their own right and, in both scenarios, appropriate legal measures are in place to safeguard the processing of your personal data.
We are committed to ensuring that your data is retained securely by us. In order to prevent unauthorised access to or disclosure of your data, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect.
Nutmeg has robust fraud screening processes to mitigate and detect fraud.
Nutmeg’s mobile apps are protected by a passcode. Nutmeg’s iOS app is compatible with Apple Touch ID.
Should Nutmeg transfer your data outside the EEA we will have appropriate additional measures in place to protect the data.
Using the internet comes with risks, we cannot guarantee that any information sent to us by email or via our website will not be intercepted or tampered with. Any communications are sent at your own risk.
There are many steps which you can take to help us keep your account safe and secure. We recommend that you take the following actions:
10.1 Password and passcode
Do not give your device security details, including any passwords or passcodes, to anyone else and don't store them on your device. Get in touch with us as soon as possible if you feel someone may know your login details or if you lose your device. We can then stop the service to your device.
For added security, we recommend you should set up a passcode to access your mobile device. This option can usually be found under the Settings menu on your device and set up multi-factor authentication via your Nutmeg dashboard.
Multi-factor authentication requires something you are, or something you have in addition to the password when you authenticate a log in to Nutmeg.
10.2 Use private browsing
Access Nutmeg using the best security offered by your browser to maintain the security of your account, this for example would be "incognito" for Google Chrome and "private browser" for Safari.
10.3 Your handset
Do not leave your device unattended when logged on and watch out for people looking over your shoulder. Think carefully before jail-breaking or rooting your device. We advise against doing this as it may weaken the security of your device and expose you to additional risks.
Where possible, keep your mobile device’s operating system updated with the latest security patches and upgrades. Older software may have security vulnerabilities that could expose you to additional risks. You may also want to consider using a reputable brand of anti-virus software on your mobile device.
10.4 When Nutmeg contacts you
We will never make unsolicited contact with you to ask you to disclose your security credentials. Be cautious about opening links contained in SMS messages or emails and beware of phishing scams.
Phishing scams are attempts by scammers to trick you into giving out personal information such as your bank account numbers, passwords and credit card numbers.
If you use Nutmeg’s mobile app, we recommend that you take these additional measures:
10.5 Passcode, TouchID and FaceID
Your Nutmeg app is protected by a passcode. We recommend that if you use Nutmeg’s apps, you use enable TouchID or FaceID for biometric entry.
10.6 App store
Only download mobile apps from official app stores.
When accessing your Nutmeg account please be vigilant about who might be able to view your screen.
- Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and review the privacy statement applicable to the relevant website.