Nume Privacy Policy

1. Purpose & Scope

This Privacy Policy explains how Nume collects, uses, stores, shares, and protects your personal data in compliance with the **UK General Data Protection Regulation (UK GDPR)** and the **Data Protection Act 2018**. It aligns with RiskSave’s policy framework and reflects our commitment to privacy, governance, and customer protection.

Note: This policy should be read together with our separate Privacy Notice, which provides additional detail on data processing for specific services, including referrals to mortgage advisors.

2. Who We Are

**Sprout Financial Ltd** (trading as “Nume”) is an Appointed Representative of RiskSave Technologies Ltd, authorised and regulated by the Financial Conduct Authority (FCA). We provide digital wealth-building tools for UK homeowners, helping you compare your property and mortgage against investment opportunities, invest directly, and access regulated mortgage advice through approved referral partners.

3. Scope and Applicability

This policy applies to:

• All personal data collected through the Nume platform (app, website, and associated services).
• All Nume employees, contractors, and third parties processing data on our behalf.

4. What Data We Collect

We collect and process the following categories of personal data:

• Identity Data: Name, date of birth, National Insurance number, ID documents.
• Contact Data: Email, phone, postal address.
• Financial Data: Income, mortgage terms, property value.
• Investment Data: Risk profile, portfolio selections, transaction history.
• Technical Data: IP address, device/browser details, session analytics.
• Property Data: Information from HM Land Registry.
• KYC/AML Data: Verification checks, anti-fraud data (via partners like Sumsub).

Note: We may be legally required to collect certain data (e.g., ID verification). Failure to provide required data may mean we cannot provide services.

5. How We Use Your Data

We use your personal information to:

• Create and manage your Nume account.
• Perform mortgage and investment comparisons and calculations.
• Connect to third-party providers (e.g., Plaid, Interactive Brokers (UK)).
• Verify your identity and comply with **FCA and AML obligations**.
• Provide insights, alerts, and recommendations.
• Meet regulatory reporting obligations (FCA, HMRC).
• Improve our platform via analytics and feedback.
• Send service updates and (with consent) marketing communications.
• Facilitate referrals to authorised mortgage advisors (e.g., Heron Financial Ltd) when you request or consent to such services.

We do not use your data for automated decision-making without your knowledge or consent.

6. Legal Basis for Processing

We rely on the following legal bases for processing your personal data:

• Contractual necessity: To deliver our services.
• Legal obligation: To meet FCA and AML requirements.
• Legitimate interests: To improve and secure the platform.
• Consent: For marketing and for sharing data with mortgage referral partners (e.g., Heron Financial Ltd).
• Vital interests: Where processing is necessary to protect someone’s life or prevent serious harm.
• Public task: Where necessary for us or our partners to perform a task in the public interest or exercise official authority (e.g., regulatory reporting or law enforcement cooperation).

7. Data Sharing

We share your data with:

• RiskSave Technologies Ltd – our FCA-regulated Principal Firm.
• KYC/AML providers – e.g., Sumsub.
• Investment partners – e.g., Interactive Brokers (UK).
• Open Banking providers – e.g., Plaid.
• Mortgage referral partner – e.g., Heron Financial Ltd (see details below).
• Cloud hosting and IT service providers – ISO27001 certified.
• Regulators – FCA, HMRC, and other authorities where legally required.

All third parties are contractually required to safeguard your data.

Mortgage Referral Partners

If you request or consent to a referral for mortgage or protection advice, Nume will share relevant information with **Heron Financial Ltd**, an FCA-authorised mortgage broker, to enable them to contact you about your mortgage needs. **Heron Financial Ltd acts as a separate Data Controller** for the personal data it receives from us. They are responsible for their own processing and will provide you with their Privacy Notice outlining how they handle your information. We only share the minimum necessary information for the referral.

8. International Data Transfers

Where personal data is transferred outside the UK, we ensure appropriate safeguards such as UK-approved Standard Contractual Clauses or adequacy decisions are in place.

9. Your Rights

You have the right to:

• Access your personal data.
• Request corrections or deletion.
• Restrict or object to processing.
• Withdraw consent at any time.
• Request data portability.

To exercise your rights, contact: admin@numewealth.com

You may also complain to the Information Commissioner’s Office (ICO) at ico.org.uk.

10. Data Security

We protect your data with:

• End-to-end encryption.
• Multi-factor authentication and strict access controls.
• ISO27001-certified storage.
• Continuous monitoring and breach protocols (aligned with RiskSave procedures).

11. Retention Policy

We retain your personal data:

• For as long as you are a Nume customer.
• For **7 years after account closure** (to meet FCA/AML obligations).
• For shorter periods where data is no longer necessary.

12. Cookies & 13. Marketing

14. Changes to This Policy

We may update this policy due to regulatory changes, internal reviews, or platform updates. We will notify you of material changes.

15. Contact Us & 16. ICO Registration

Note: This Privacy Policy should be read alongside our separate Privacy Notice, which provides more detailed information about how personal data is processed for investment, open banking, and mortgage referral services.