Privacy notice

Who we are

Steer Financial Ltd is registered in England and Wales (company number TODO-COMPANY-NUMBER; registered office TODO Registered office address, United Kingdom) and with the Information Commissioner's Office (TODO-ICO-REF). For anything in this notice, contact privacy@wealthsteer.com.

Two roles: controller and processor

WealthSteer is used by financial advice firms to engage their clients. Which role we play depends on whose data it is:

• Clients of an advice firm: the firm is the data controller and we process client data on the firm's instructions under a Data Processing Agreement. Your adviser's firm decides why your data is collected and how long it is kept; their privacy notice applies alongside this one. We never use client data for our own purposes except in aggregated, anonymised form (see "Benchmarking" below).
• Advisers and firm staff: when you create or use a WealthSteer account we are the controller for your account data (name, work email, job title, role, sign-in activity).
• Website visitors and enquiries: when you register interest, book a walkthrough or contact us, we are the controller for what you give us.

What we collect

• Account data: name, email address, job title, firm, role, and sign-in events (we use passwordless sign-in links — we never store a password).
• Client engagement data (on behalf of a firm): the client's name and email as entered by the firm; questionnaire answers and the resulting scores; financial facts the client chooses to share (income, outgoings, savings, investments, pensions, property, debts, protection); adviser notes addressed to the client.
• Enquiries: name, email, firm name, and what you tell us about your firm (for example the CRM you use).
• Technical data: IP address and browser details in server logs for security and reliability; aggregate, cookieless page analytics on our marketing pages.

Why we use it and our lawful bases

• Providing the service to firms and their clients — performance of a contract (with the firm) and, for client data, the firm's instructions as controller.
• Security, fraud prevention, and keeping the platform reliable — our legitimate interests.
• Responding to enquiries and telling firms about the product they asked about — legitimate interests; you can ask us to stop at any time.
• Benchmarking: producing anonymised, aggregated statistics about financial confidence (for example a published index). No individual or firm is identifiable in these statistics; small groups are suppressed. Legitimate interests, and a core purpose of the platform that firms agree to in their DPA.
• Legal obligations — record-keeping and responding to lawful requests.

Where your data lives

Platform data is stored in the United Kingdom (Supabase, AWS London region). Email is sent through Resend, which may process message data in the United States under the UK International Data Transfer Addendum / Standard Contractual Clauses. Our full list of sub-processors is on the Data Processing Agreement page and is kept current.

How long we keep it

• Client data held for a firm: for as long as the firm's agreement with us lasts and then deleted or returned within 30 days of the firm's instruction. Scores and statements are kept as an immutable history while the account is live because the service is a record of change over time.
• Adviser accounts: for the life of the firm's subscription and a short period after, then deleted.
• Enquiries: up to 24 months from last contact, unless you become a customer.
• Server logs: 30 days.

Sharing

We share data only with the sub-processors who run the platform for us (listed on the DPA page), with your adviser's firm where it is their data, and where the law requires. We do not sell personal data and we do not share client data with any other advice firm, including any firm connected to our group.

Your rights

You can ask for access to your data, correction, deletion, restriction, portability, or object to processing based on legitimate interests. If you are a client of an advice firm, the quickest route is your adviser — they control your record — but you can contact us at privacy@wealthsteer.com and we will help or pass the request on. You also have the right to complain to the ICO (ico.org.uk).

Guidance, not advice

Nothing produced by WealthSteer — scores, statements, calculators or insights — is regulated financial advice or a personal recommendation. It is information to help you and your adviser have a better conversation.

Changes

We will post any changes here with a new date. Material changes affecting firms are also notified to the firm's administrator.