Privacy Notice

Purpose

This privacy notice applies to personal data we collect solely to perform anti-money laundering ('AML') and know-your-customer ('KYC') checks. We do not collect or process personal data for any other purpose, (e.g., marketing, profiling or website analytics).

Controller

Wagglyn is the data controller for the purposes of UK data protection legislation and determines how and why your personal data is processed.

What data do we collect?

We collect and process the following categories of personal data to conduct our checks:

• Identity data – e.g. full name, date of birth, nationality, gender
• Contact data – e.g. residential address, email address, phone number
• Verification documents – e.g., passport, driving licence, utility bill, or other identity documents
• AML data – e.g., identity verification results and risk scoring as provided by our third-party verification service

How do we collect your data?

We collect this data directly from you and may verify it using a secure third-party AML/KYC provider such as Veriphy.

What's our legal basis for processing?

We process your personal data based on our legitimate interests in:

• Verifying the identity of individuals we advise
• Assessing financial crime or reputational risk
• Protecting our business against fraud or misuse of services

We believe this is necessary and proportionate, and that your privacy rights do not override these interests. You have the right to object to this processing at any time.

Who do we share your data with?

We only share your personal data with:

• Our AML/KYC provider (Veriphy) who acts as a data processor under contract
• Our professional advisors and/or legal/regulatory bodies if required in the context of a dispute, risk or audit

International transfers

Your personal data may be transferred outside the UK. Where this occurs, we ensure appropriate safeguards are in place, such as the UK International Data Transfer Agreement.

How long do we keep your data?

We retain your personal data for up to 5 years from the date of collection or from the end of our professional relationship, whichever is later, to maintain compliance with best practice and to defend against legal claims if necessary.

Your rights

Under UK data protection law, you have the right to:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Withdraw consent

You also have the right to make a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk

If you wish to exercise any of the rights set out above, please contact info@wagglyn.com

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact us

If you have any questions about this notice or how we handle your data, email info@wagglyn.com

Changes to this privacy notice

We may update this privacy notice from time to time to reflect changes in our business operations, legal obligations or best practice. Where material changes are made, a copy of the updated privacy notice will be provided to the data subjects directly, and the effective date will be clearly stated. We encourage you to review any updates carefully.