Who we are
Alder Wealth is a trading name of Punk AI Wealth Technologies Ltd (“we”, “us”, “our”), a company registered in England and Wales. We are the data controller responsible for your personal data.
What data we collect
When you use Alder, we collect information you provide during the onboarding conversation, including:
- Name and email address
- Financial profile information: income, investable assets, employment status, tax residency
- Investment preferences: risk appetite, time horizon, ESG preferences, tax wrapper status
- Conversation history with our AI assistant
- Documents you choose to upload (e.g. payslips, pension statements)
We also collect technical data automatically: IP address, browser type, device information, and usage analytics.
How we use your data
We use your personal data to:
- Generate personalised portfolio illustrations based on your financial profile
- Provide daily AI monitoring and intelligence briefings for your portfolio
- Connect you with FCA-authorised wealth managers and share your briefing pack with them
- Improve our AI models and portfolio generation algorithms (using anonymised, aggregated data only)
- Communicate with you about your account and portfolio alerts
- Comply with our legal and regulatory obligations
Legal basis
We process your data on the following legal bases under UK GDPR:
- Contract: Processing necessary to provide our service to you
- Consent: Where you have given clear consent for specific processing (e.g. marketing communications)
- Legitimate interest: Improving our services, security, and fraud prevention
- Legal obligation: AML/KYC checks, regulatory reporting, tax reporting obligations
Who we share your data with
We share your financial profile and portfolio data with:
- Partner IFA firms: FCA-authorised wealth managers who review your portfolio and provide regulated advice. They receive a briefing pack containing your financial profile and AI-generated portfolio.
- Infrastructure providers: Cloud hosting (Cloudflare), authentication (Clerk), payment processing (Stripe), and analytics providers. These processors act on our instructions and have appropriate data processing agreements in place.
- AI service providers: Our AI models are provided by Anthropic. Conversation data is processed to generate portfolio illustrations. We do not allow AI providers to use your data for training their general models.
We never sell your personal data to third parties.
Data retention
We retain your personal data for as long as your account is active, plus a minimum of 6 years after closure to comply with financial services record-keeping obligations. Anonymised analytical data may be retained indefinitely.
Your rights
Under UK GDPR, you have the right to:
- Access the personal data we hold about you
- Rectify inaccurate or incomplete data
- Erase your data (subject to regulatory retention requirements)
- Restrict or object to processing
- Data portability — receive your data in a structured, machine-readable format
- Withdraw consent at any time (where processing is based on consent)
To exercise any of these rights, contact us at [email protected].
Security
We implement appropriate technical and organisational measures to protect your personal data, including encryption in transit and at rest, access controls, regular security assessments, and incident response procedures.
International transfers
Some of our infrastructure providers are based outside the UK. Where personal data is transferred internationally, we ensure appropriate safeguards are in place, including Standard Contractual Clauses and adequacy decisions.
Cookies
We use essential cookies required for the service to function, and optional analytics cookies with your consent. You can manage your cookie preferences at any time through your browser settings or our cookie banner.
Changes to this policy
We may update this policy from time to time. Material changes will be communicated via email or in-app notification. The “last updated” date at the top reflects the most recent revision.
Contact
For privacy-related enquiries: [email protected]
If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk.