Privacy Policy

Wagestream Asset Management Privacy Notice

Your privacy is important to us, so we’ve created a policy that covers how we collect, use and store personal data.

Last updated: 25^th July 2025

Please read this privacy notice (“Privacy Notice”) carefully as it describes our collection, use, disclosure, retention and protection of your Personal Data.

Wagestream Asset Management respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our platform, mobile application (“App”) and/or website(s) (together “Platform”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Notice describes how Wagestream Asset Management collects and processes your Personal Data, which may be either through your use of the Wagestream Platform, including any data you may provide through this Platform; or through your interaction with Wagestream Asset Management through social media and marketing activities. The Privacy Notice complies with and is intended to meet our duties of Transparency under the retained EU law version of the General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018 (as amended from time to time).

It is important that you read this Privacy Notice together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. This Privacy Notice supplements other such notices and is not intended to override them.

Where you provide us with your Personal Data in any of the ways described in the section “Who we are and how to contact us” below, you agree that we may collect, store and use it: (a) in order to perform our contractual obligations to you; (b) based on our legitimate interests for processing (i.e. for internal administrative purposes, data analytics and benchmarking (see section 3 below for more information), direct marketing, maintaining automated back-up systems or for the detection or prevention of crime); or (c) based on your consent, which you may withdraw at any time, as described in this Privacy Notice.

Who we are and how to contact us

This Privacy Notice applies to all products, applications and services offered by Wagestream Asset Management Ltd (WAM), (a company incorporated in England with company registration number 10970025) and whose registered office address is 7-9 Rathbone Street, London, W1T 1LY, but excludes any products applications or services that have separate privacy notices which do not incorporate this Privacy Notice.

We are registered with the Information Commissioner’s Office (“ICO”) with reference number: ZA429719 (Wagestream Asset Management Ltd).

For services that are not provided by Wagestream Asset Management (e.g. Flexible Pay and other services provided through the Wagestream App) please see the Wagestream Ltd privacy notice.

The privacy notice applicable to the provision of regulated products and services (e.g. credit cards, loans and workplace savings) is provided by Wagestream Finance Limited.

How to contact us

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about it, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

You can contact us through the App or website; by emailing: [email protected]; or writing to us at DPO, Wagestream, 7-9 Rathbone Street, London, W1T 1LY.

What Personal Data we collect

The types of Personal Data we may collect about you, is outlined in the table below.

Category of Personal Data collected	What this means
Identity Data	includes full name; username or similar identifier; title; date of birth; gender; age; nationality and language(s); passport, driving licence or other identity document, which includes a photograph (for KYC, AML checks, and profile picture where added), National Insurance Number.
Contact Data	includes your home address; email address and telephone number.
Profile Data	includes your password, your interests, preferences, feedback and survey responses.
Other Personal Data	includes data provided to customer services support including about personal circumstances, which may include additional financial information such as household income; financial income other than salary; financial liabilities.
Employment Data	includes Employee ID; income; employment status; shifts and hours; absences, name of employer, place of work, employment history, start date, and termination date.
Financial Data	includes sort code; account name; account number; salary and statutory payments.
Open Banking Data	includes transaction history; transaction amounts and descriptions; account name; account number; account balance; currency; overdraft availability and balance; payment due dates and other information about your transactions, such as fees and account charges.
Transaction Data	includes any details about payments to and from you; other details of our services you have used and your transactions with 3rd parties.
Behavioural Data	includes inferred or assumed information relating to your behaviour and interests; based on your online activity and/or in App. This is most often collated and grouped into “segments” (e.g., there may be a segment for users, living in London and aged under 25, who use our services twice a month).
Technical	includes data related to website visits and App usage, such as Internet Protocol (IP) address; mobile device identifier; your login data; browser type and version; time zone setting and location; device language settings; browser plug-in types and versions; download errors; response time; page interaction (such as scrolling, clicks, and mouse-overs) device type and model; operating system and platform and other technology on the devices you use to access this Platform or use our services.
Marketing and Communications Data	includes your preferences in receiving marketing from us and third parties and your communication preferences; our communications with you (which may include correspondences, call and video records, transcriptions and analysis thereof).
Health Data	Includes data about your health such as any sensitive health information that you provide us during conversations with our support team, or any other communications that may reveal your vulnerability status, such as a gambling addiction, or other health issues
Account Activity Data	includes your name, date of birth but also your current and past (i) address details, (ii) employment status (including your role, starting & ending date(s), number of worked hours), (iii) employer details, salary/earning/payroll details (including but not limited to payment dates and frequencies, gross and net salary/earnings information, tax related details).
Pension Data	includes pension scheme name(s); pension policy number(s); type of pension plan; charges, including any exit fees; transfer value; any restrictions or safeguarding benefits; and any other pension details.
Letter of Authority Data	includes a copy of your signature, collected for the purpose of creating Letters of Authority to be submitted to pension providers, enabling us to request information about your pension schemes on your behalf.

Aggregated Data

We may use and share Personal Data as “Aggregated Data” for statistical purposes only. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the UK GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.

Special Categories of Personal Data

We may need to process sensitive information about you that data protection laws call “Special Category” data. This is information that can reveal details about a person’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about health and genetic data.

Our reasons for using Special Category Data

Face / Biometric Data – As Wagestream is a financial services provider, we are required to undertake Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance checks if you open a Build Pot, Savings Account, or apply for a credit product.

Our third-party partner Onfido collects facial biometric data for the purposes of completing the KYC and AML checks, by comparing a photograph of your identity document, against a photograph of you to allow verification of your identity. Onfido stores this data for up to three years for legal and compliance purposes. See Onfido’s Privacy Notice. Wagestream does not store this data.

We may also collect and process Health Data where you or your employer provide us with the same for the purposes of protecting your financial wellbeing if you are at risk.

We will record any issues you tell us about if they involve special category (i.e., sensitive) personal information, such as a gambling addiction or information about your health. We do this to comply with the FCA’s rules and expectations, which require us to understand and support customers with characteristics of vulnerability. We will only collect and process special category data that is necessary to meet our obligations and to provide appropriate support. We will ensure that the data collected is proportionate to the purpose. This information will be used to tailor our services, and ensure fair treatment. We rely on Article 9(2)(g) UK GDPR / paragraph 19 of Schedule 1 of the DPA 2018 (safeguarding of economic wellbeing) and Article 9(2)(g) / paragraph 9 of Schedule 1 of the DPA 2018 (equality of opportunity or treatment) as the legal basis for processing this data

We may share information about you externally where we deem it is necessary to protect your vital interests or the vital interest of another person.

How we collect your Personal Data

Directly

Directly from you via in-App chat, by filling in forms or by corresponding with us by post, phone, email, social media channels or otherwise. This includes, without limitation, Personal Data you provide when you:

enrol in our services;
create an account;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.

Automated technologies or interactions

As you interact with the Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. For more details, please see the Cookies section. You can read our full Cookie Notice in our Cookie Notice page.

From third party sources

We may enhance Personal Data we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from other Wagestream group companies, credit agencies, search information providers or public sources (e.g. for customer due diligence purposes), but in each case as permitted by applicable laws.

How we use Personal Data

To the extent permissible under applicable law, we use your information to:

provide any information and services that you have requested or any applications or services that you have ordered;
compare information for accuracy and to verify it with third parties;
provide, maintain, protect and improve any applications, products, services and information that you have requested from us;
manage and administer your use of applications, products and services you have asked us to provide;
manage our relationship with you (for example, customer services and support activities);
monitor, measure, improve and protect our content, website, applications and services and provide an enhanced, personal, user experience for you;
undertake internal testing of our website, applications, systems and services to test and improve their security, provision and performance, in which case, we would pseudonymise any information used for such purposes, and ensure is it only displayed at aggregated levels which will not be linked back to you or any living individual;
provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);
contact you to see if you would like to take part in our customer research (for example, feedback on your use of our applications, products and services);
to monitor, carry out statistical analysis and benchmarking, provided that in such circumstances data will either be fully anonymised, or pseudonymised.
deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of our applications and services;
deliver joint content and services with third parties with whom you have a separate relationship (for example, social media providers); and
provide you with location- based services (for example, advertising and other personalised content), where we collect geo-location data.

Our Platform (including mobile applications) and services may contain technology that enables us to:

check specific information from your device or systems directly relevant to your use of the websites, applications or services against our records to make sure the websites, applications or services are being used in accordance with our end-user agreements and to troubleshoot any problems;
obtain information relating to any technical errors or other issues with our website, applications and services;
collect information about how you and users use the functions of the features of our website, applications and services; and
gather statistical information about the operating system and environment from which you access our applications or services.

You can manage your privacy settings within your browser or our applications and services (where applicable).

In addition to the purposes described in this section, we may also use information we gather to deliver targeted advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the website, applications or services or any other information we have about you (depending on the websites, applications or services, you may able to configure these features to suit your preferences). The “Who we share your Personal Data with”, and “Marketing” sections of this Privacy Notice provides further details on how we will do this.

We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website, applications and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.

Automated Decision Making & Profiling

Wagestream Asset Management undertake an automated Know Your Customer (KYC) check in order to check your identity and confirm your eligibility for this product.

We may also use aggregated data for internal analysis and to inform marketing strategies.

Other parts of the Wagestream group of companies also use automated decision making and profiling, and this is documented in their respective privacy notices.

You can request a member of the team to review an automated decision by contacting customer support via Help in the app, or at [email protected].

Use of Artificial Intelligence (AI)

Wagestream uses AI to automate certain parts of the pension finding journey, such as validating data that you have provided, and contacting pension providers, to improve speed and efficiency. AI is also used to enhance and streamline our customer support interactions, including providing automated assistance and personalised responses. This involves the AI-powered analysis of conversations (including calls, video records, and transcriptions) and other data provided to offer relevant support and advice.

Mobile Data

We may obtain information through mobile applications that you install on your mobile device to access and use our website, applications or services or which you or your users use to provide other services related to that mobile application (for example, to sync information from our application or service with such mobile application). These mobile applications may be our own mobile applications or those belonging to third parties. Where the mobile application belongs to a third party, you must read that third party’s own privacy notice as it will apply to your use of that third party mobile application. We are not responsible for such third-party mobile applications and their use of your Personal Data.

Mobile applications may provide us with information related to a user’s use of that mobile application and use of our applications and services accessed using that mobile application. We may use such information to provide and improve the mobile application or our own application or services. For example, activity undertaken within a mobile application may be logged.

You can configure our mobile application’s privacy settings on your device but this may affect the performance of that mobile application and the way it interacts with our applications and services.

Data analytics and benchmarking

We may use information generated and stored during your use of our services for our legitimate business interests to enable us to give you the best service and/or solutions and the best experience. These purposes include to:

deliver advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of services;
carry out research and development to improve our services, products and applications;
develop and provide new and existing functionality and services (including statistical analysis, benchmarking and forecasting services); and
provide you with location-based services (for example location relevant content) where we collect geo-location data to provide a relevant experience.

Whenever we use your information for research, we will ensure that your information is processed on a pseudonymised basis and displayed at aggregated levels, which will not be linked back to you or to any living individual.

Who we share your Personal Data with

We may share your Personal Data with members of our group of companies (including, but not limited to, Wagestream Ltd, Wagestream, Inc., and Wagestream Finance Ltd). This is in order to:

provide you with the best service;
protect you, other customers and our systems from fraud or harmful behaviour;
facilitate you quickly signing up to use other Wagestream products or services;
improve existing, or develop new products or services
transfer information for reporting, regulatory or transaction processing purposes; and
send you information about Wagestream products and services we think you’ll be interested in hearing about if you have consented to receive these communications.

We may also share your information with:

Quai Investment Services Limited (Quai) - 09919243 and the registered address is: Unit 16 Tesla Court, Innovation Way, Peterborough, PE2 6FL for the provision of pension consolidation services
Your employer. Your employer(s) engaged Wagestream to provide the Platform and Wagestream services. We share your Personal Data with your employer(s) to provide them and you with such Platform and services.
Partners. Where partners provide elements of our, or ancillary, services
Service providers. For the provision of IT and system administration services, email service providers, marketing service providers, customer services, KYC and AML service providers, to support our products and services, and other support services which allow us to run the business.

Third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries

Professional advisers. For the provision of consultancy, banking, legal, insurance, accounting and similar services
HM Revenue & Customs, regulators and other authorities acting as processors, and our principals, who require reporting of processing activities in certain circumstances.
Pension Providers:. We will share relevant data with pension providers, to obtain and/or ascertain the existence of any, and all information about your pension plans.
Research Institutions:- To further understanding of the financial poverty premium, and financial wellbeing, we engage with trusted institutions to undertake financial research. Data will either be fully anonymised, or pseudonymised.
with our instructions.
Credit reference and fraud prevention agencies
Law enforcement agencies so that they may detect or prevent crime or prosecute offenders
Any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order)
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Notice.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Behavioural, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications (including by email and push notification) from us if you have requested information from us or obtained services from us and you have not opted out of or unsubscribed from receiving that marketing.

You will receive marketing communications by text and/or WhatsApp only where you have consented to receive the same.

Third-party marketing

We will get your express opt-in consent before we share your Personal Data with any third party for their marketing purposes.

Your rights relating to your Personal Data

You have certain rights under the law, such as notice to request access to your information, to manage it and to request for it to be deleted or to transfer information about you or to restrict the way it is used.

By law you have the right to:

Request access to your Personal Data. This is commonly known as a “data subject access request” and enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below). Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest (or those of a third party) as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Platform. We will advise you if this is the case at the time you withdraw your consent.
Object to any decisions based on the automated processing of your Personal Data, including profiling; and

You have the right to make a complaint at any time to the ICO, the UK regulator for data protection issues, (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

How to exercise your rights

Please contact us using the contact details shown in “Who We Are and How to Contact Us”.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee, or refuse to comply with the request, if it is unfounded, repetitive or excessive.

We may need to request specific information from you to help us confirm your identity to exercise any of your rights, including those related to data protection). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. We will post any changes to this Privacy Notice on this page.

How we keep your Personal Data secure

We have put in place appropriate technical and operational security measures designed to prevent your Personal Data from loss, misuse, alteration or destruction. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. If you suspect any misuse or loss of, or unauthorised access to, your Personal Data, you should let us know immediately.

How long do we store your Personal Data?

We will store your information for a period of seven years after our business relationship ends in order that we can comply with our obligations under applicable legislation such as anti-money laundering and anti-fraud regulations. If any applicable legislation or changes to this require us to retain your data for a longer or shorter period of time, we shall retain it for that period. We will not retain your data for longer than is necessary.

International data transfers

Many of our external third parties are based outside the UK so their processing of your Personal Data will involve a transfer of data outside the UK.

Wagestream Asset Management shall not transfer your Personal Data outside of the UK or the European Economic Area (EEA) unless it has taken such measures as are necessary to ensure the transfer is in compliance with applicable data protection laws (including EU GDPR and the Data Protection Act 2018/UK GDPR, in each case as in force and applicable, and as may be amended, supplemented or replaced from time to time) Such measures may include (but are not limited to) transferring your Personal Data to a recipient in a country that the UK or European Commission (respectively) has decided provides adequate protection for Personal Data, to a recipient that has achieved binding corporate rules authorisation in accordance with applicable data protection laws, or to a recipient that has executed standard contractual clauses adopted or approved by the UK or European Commission (respectively).

Third party links

This Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the Privacy Notice of every site you visit.

Further information

If you have any queries about how we treat your information, the contents of this Privacy Notice, your rights under the law, how to update your records or how to obtain a copy of the information that we hold about you, please write to our DPO at, Wagestream, 7-9 Rathbone Street, London, W1T 1LY or send an email to [email protected]

Welcome to Wagestream Asset Management’s Privacy Notice