Last updated: 11 March 2026
1. Who We Are
This privacy policy covers the Altor WM Client Portal mobile application (“the App”), operated by Altor Wealth Management LLP (“Altor”, “we”, “us”). Altor Wealth Management LLP is registered in England and Wales. Our registered address is Landmark House, Station Road, Hook, RG27 9HA.
For privacy enquiries: info@altorwealth.co.uk
2. What Data The App Collects
When you use the App, we collect and process the following:
- Identity and contact data – your name and email address, provided when your adviser sets up your account
- Authentication data – login credentials and secure session tokens, stored encrypted on your device
- Financial planning data – documents, financial plans, and information shared with you by your adviser through the platform
- Messages – communications sent between you and your adviser through the in-app messaging feature
- Device data – device type, operating system version, and push notification token (to deliver notifications)
- Usage data – how you interact with the App (e.g. which sections you access), used to improve the service
3. Biometric Data
The App offers Face ID / Touch ID as an optional convenience feature for login. Biometric authentication is handled entirely by your device’s operating system (Apple iOS), and your biometric data is never transmitted to or stored by Altor or Ningi.
4. How We Use Your Data
We use your data to:
- Provide you with secure access to your financial planning information
- Enable communication between you and your adviser
- Send you push notifications about updates to your plan or messages from your adviser
- Maintain the security of your account
- Comply with our legal and regulatory obligations as an FCA-regulated firm
We do not sell your data to third parties or use it for marketing purposes without your consent.
The legal bases for processing your data are as follows:
- Performance of a contract: To provide secure access, enable communication, and send notifications related to your financial planning services.
- Legitimate interests: To maintain account security, improve the service via usage data, and for internal analytics (you have the right to object to this processing—see Section 7).
- Legal obligation: To comply with FCA regulations.
- Consent: For optional features like biometric login or any marketing communications (you can withdraw consent at any time—see Section 7).
5. Who We Share Your Data With
Your data is processed on infrastructure provided by:
- Ningi – the technology platform that powers the App. Ningi acts as a data processor on behalf of Altor.
- Apple – device and push notification services
- Expo (by Expo Technology Inc.) – used for delivering push notifications
All third-party processors are subject to data processing agreements and are obligated to handle your data securely and in accordance with applicable law. Some of our processors (e.g., Apple and Expo) are based outside the UK, in countries like the US. We ensure appropriate safeguards are in place for these transfers, such as the UK International Data Transfer Agreement (IDTA) or standard contractual clauses approved by the UK Information Commissioner’s Office (ICO).
6. Data Retention
Your data is retained for as long as you have an active client relationship with Altor, and for a further period as required by FCA regulations (typically 5-7 years). You may request deletion of your account data by contacting us.
7. Your Rights
Under UK GDPR, you have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate data
- Request deletion of your data (subject to regulatory retention requirements)
- Object to or restrict processing
- Withdraw consent where processing is based on consent
- Contest and request intervention where there is automated decision-making
- Lodge a complaint with the ICO (ico.org.uk)
To exercise any of these rights, contact us at info@altorwealth.co.uk.
8. Automated Decision-Making
The App includes features that use automated processing to generate personalised financial guidance. You may be asked to complete a short questionnaire about your financial situation, goals, and risk tolerance. Your responses are then processed by an algorithm to produce tailored suggestions – such as whether to prioritise debt repayment or consider investing, and if so, which types of products may be suitable for you.
These outputs are generated automatically based on the information you provide, but they do not replace personal financial advice from your adviser. Your adviser retains oversight of any recommendations, and no automated decision will result in action being taken on your behalf without appropriate human review.
Under UK GDPR (Article 22), you have the right to:
- Request human intervention in any automated decision
- Express your point of view
- Contest any automated output
To exercise these rights, contact us at info@altorwealth.co.uk.
9. Security
We take the security of your financial data seriously. The App uses encrypted storage for credentials, secure HTTPS communications, and optional biometric authentication. Access to your data is restricted to your adviser and authorised Altor staff.
10. Changes to This Policy
We may update this policy from time to time. We’ll notify you of significant changes through the App or by email.
11. Contact
Altor Wealth Management LLP
Landmark House, Station Road, Hook, RG27 9HA