Privacy Policy

The services and investments advisory referenced in this website should not be regarded as an offer of solicitation for such services or investment advisory in any jurisdiction where such activity is unlawful. This website is not directed at you, if we are prohibited by any law of any jurisdiction from making the information on this site available to you and is not intended for any use which would be contrary to local law or regulation.

The promotion of these services and advisory is restricted to clients who are experienced investors (Professional clients or Eligible counterparties as defined by the FCA) in these types of investments. This website and its contents are not intended to sell services or products over the internet, rather for internet viewer convenience and informational purposes. Subscriptions will only be received and shares issued on the basis of the current prospectus or Scheme Particulars for the fund. Every effort has been made to ensure the accuracy of the financial information herein but it is based on unaudited figures.

Past performance is not a guarantee of future performance. It should be remembered that the value of investments may fall as well as rise, investors may not get back the amount of money invested, currency movements may have a negative as well as positive influence on returns and past performance is not necessarily an indicator of future performance. Any investment decision should be made solely on the basis of the information and risk warnings contained within the information memorandum and/or prospectus issued by or on behalf of the fund or company concerned.

The Wealth Advisory Partners services are not available for purchase by US persons. Services or advisory described on this website are not available for sale in any jurisdiction in which sale would be prohibited. Nothing in this website constitutes investment, legal, tax or other advice nor is it to be relied upon in making an investment decision. Please note that authorization by the FCA does not imply official approval or recommendation.

The information contained in this website shall not be published, rewritten for broadcast or publication or redistributed in any medium without prior written permission from 1848 Founders Capital.

Wealth Advisory Partners is authorized and regulated by the Financial Conduct Authority.

Privacy Policy

Wealth Advisory Partners Website: https://wa-partners.com

Last updated: [20 August 2026]

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1. Introduction

[Wealth Advisory Partners] ("we", "us", "our") is committed to protecting your privacy and handling your personal data in an open and transparent manner. This Privacy Policy explains how we collect, use, disclose and safeguard your personal data when you visit wa-partners.com (the "Website"), enquire about or use our services, or otherwise interact with us.

We are authorised and regulated by the Financial Conduct Authority (FCA) [FRN: [number]] and [where applicable] BaFin, and we process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), the Data Protection Act 2018, and other applicable data protection laws.

Please read this policy together with our Cookie Policy and any other notices we may provide on specific occasions.

2. Who is responsible for your data (Data Controller)

For the purposes of applicable data protection law, the data controller is:

[Wealth Advisory Partners legal entity name] [Registered office address] Company/registration number: [number] Email: [privacy@wa-partners.com]

If we have appointed a Data Protection Officer (DPO) or a representative in the UK/EU, their contact details are:

[DPO / representative name and contact details, if applicable]

3. The personal data we collect

We may collect and process the following categories of personal data:

• Identity data – name, title, date of birth, nationality, and identification documents (e.g. passport, driving licence) collected for identity verification.
• Contact data – postal address, email address and telephone numbers.
• Financial data – bank account details, source of funds/wealth, tax residency and identifiers, investment history and holdings.
• Suitability and profile data – investment objectives, risk appetite, knowledge and experience, and client classification (e.g. Professional client / Eligible counterparty).
• Transaction data – details of subscriptions, redemptions, payments and communications with us.
• Verification and compliance data – information collected to meet our legal obligations, including anti-money laundering (AML), know-your-customer (KYC), sanctions and politically-exposed-person (PEP) screening results.
• Technical and usage data – IP address, browser type, device information, and how you use our Website (collected via cookies – see our Cookie Policy).
• Communications data – records and copies of correspondence, and (where permitted and notified to you) recordings of telephone calls.

We generally do not seek to collect special category data (e.g. data about health, race or political opinions). Where we do need to, we will do so only where permitted by law and, where required, with your explicit consent.

4. How we collect your data

We collect personal data:

• Directly from you – when you complete forms, correspond with us, apply for or use our services, or otherwise provide information.
• Automatically – as you interact with our Website, through cookies and similar technologies.
• From third parties – including identity-verification and credit-reference agencies, sanctions and PEP screening providers, public registers, your professional advisers, introducers, and other financial institutions.

5. How we use your data and our legal bases

We will only use your personal data when the law allows us to. Most commonly, we rely on the following legal bases under the UK/EU GDPR:

Where we rely on legitimate interests, we have carried out a balancing assessment to ensure our interests are not overridden by your rights. Where we rely on consent, you may withdraw it at any time (see Section 11).

6. Marketing communications

Where permitted, we may send you information about our services and market insights that may be of interest to you. You can opt out of marketing at any time by using the unsubscribe link in our communications or by contacting us at [privacy@wa-partners.com]. Opting out of marketing will not affect communications relating to services we provide to you or our legal obligations.

7. Who we share your data with

We may share your personal data with:

• Service providers and processors acting on our behalf (e.g. IT, hosting, communications, identity-verification and compliance-screening providers), who are bound by confidentiality and data protection obligations.
• Fund administrators, custodians, banks and other financial institutions involved in providing our services.
• Professional advisers, including lawyers, auditors and accountants.
• Regulators, tax authorities and law-enforcement bodies, including the FCA, BaFin, HM Revenue & Customs and equivalent authorities, where required by law.
• Third parties in connection with a corporate transaction, such as a merger, acquisition or reorganisation.

We require all third parties to respect the security of your data and to treat it in accordance with the law. We do not sell your personal data.

8. International transfers

Your data may be transferred to, and processed in, countries outside the UK and the European Economic Area (EEA). Where we transfer personal data internationally, we ensure an appropriate level of protection is in place, such as:

• transfers to countries with an adequacy decision; or
• the use of Standard Contractual Clauses (SCCs) and, for UK transfers, the UK International Data Transfer Agreement (IDTA) or Addendum, together with any additional safeguards required.

You may request a copy of the relevant safeguards by contacting us.

9. How long we keep your data

We keep personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, regulatory, accounting or reporting requirements.

As a regulated financial firm, we are generally required to retain certain records for a minimum of five (5) years after the end of our business relationship (and in some cases longer, e.g. for AML or where required by the FCA/MiFID II). After the applicable retention period, we will securely delete or anonymise your data.

10. How we protect your data

We have implemented appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, loss or destruction. These include access controls, encryption where appropriate, staff training and confidentiality obligations. Where we have given you (or you have chosen) a password to access certain parts of our services, you are responsible for keeping it confidential.

11. Your rights

Subject to certain conditions and exemptions under data protection law, you have the right to:

• Access – request a copy of the personal data we hold about you;
• Rectification – ask us to correct inaccurate or incomplete data;
• Erasure – ask us to delete your data ("right to be forgotten");
• Restriction – ask us to restrict processing in certain circumstances;
• Portability – receive certain data in a structured, machine-readable format;
• Object – object to processing based on legitimate interests, and to direct marketing;
• Withdraw consent – where our processing is based on consent; and
• Not be subject to solely automated decisions that produce legal or similarly significant effects (see Section 12).

Please note that some of these rights are limited where we are legally required to retain your data (for example, to meet AML and FCA obligations). To exercise any of these rights, contact us at [privacy@wa-partners.com]. We will respond within the timeframes required by law (normally one month). We do not charge a fee unless your request is clearly unfounded or excessive.

12. Automated decision-making and profiling

We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing.

 

13. Children

Our Website and services are directed at professional and eligible-counterparty clients and are not intended for children. We do not knowingly collect personal data from anyone under the age of 18.

14. Third-party links

Our Website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites, and we encourage you to review their privacy policies.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with a revised "Last updated" date. Where changes are significant, we will provide a more prominent notice.

16. How to contact us and complaints

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact:

[Wealth Advisory Partners] [Registered office address] Email: [privacy@wa-partners.com] [Data Protection Officer / contact, if appointed]

You also have the right to lodge a complaint with a supervisory authority:

• UK: Information Commissioner's Office (ICO) – https://ico.org.uk – 0303 123 1113
• Germany / EU: your local data protection authority

We would, however, appreciate the chance to address your concerns before you approach the regulator, so please contact us in the first instance.