Privacy Policy

1. General

1.1. We are Scalable Capital Limited (referred to as “we” or “us” or “our”). Scalable Capital Limited’s registered address is at 4 Christopher Street, London, EC2A 2BS and its registration number is 9386303. Scalable Capital Limited is committed to protecting and respecting your privacy. For the purposes of the Data Protection Act 1998, we are the data controller and we are registered with the Information Commissioner’s Office (registration number: ZA106483).

1.2. We provide a platform via our website, (“Website”) and our app (“App”) for providing discretionary investment management services. Any reference to the Website in this privacy Policy shall also include the App. These Terms apply to actual clients (“Investors”) and anyone simply browsing our Website (“Guest”) (either one referred to as “you” or “your”).

We have appointed an external data protection officer (DPO). His contact details are as follows:

Data Protection Officer
Mr Helge Kauert
dataLEGAL Rechtsanwaltsgesellschaft mbH
Oskar-von Miller-Ring 33
80333 Munich, Germany

1.3. Please read this policy (“Privacy & Cookie Policy”) carefully as it sets out the basis on which we collect any personal information from you when you use our Website and how we use it. We will ask you to consent to our Website Terms and our Privacy & Cookies Policy when you first visit our Website. If you click “OK” or continue to browse and use the Digital Platform, you are agreeing to comply with and be bound by these Website Terms and our Privacy & Cookie Policy.

1.4. We may change this Privacy & Cookie Policy from time to time by updating this page. You should check this page from time to time to ensure you are happy with any changes. If you have any questions about this Privacy & Cookie Policy, please contact us at

2. What information do we collect from users of the Website, including Guests?

2.1. You can browse this Website as a Guest without giving us any information, and we won’t know who you are. However, even if you are a guest, please bear in mind that we may:

  • record the areas of the Website which you visit and at what times;
  • record information about your activities in using the Website; and
  • collect information about your computer, such as which browser you are using, your network location, your operating system, your IP address and the type of connection you are using (e.g. broadband, ADSL etc.); and
  • store data that you submit to us via email, via our optional surveys, and through our contact form on the Website.

2.2. We collect the information above by using cookies. Please see below for details on cookies.

3. What information do we collect from Investors?

3.1. Additional services are available once you register with us and login to the Website. In this case, we will know who you are, your activities on the Website and information about your computer may be linked to you on our systems. We will also store any data you upload to the Website (for example documents required for identification verification purposes).

3.2. The types of information we may request are, inter alia:

  • contact information;
  • marital status;
  • personal details;
  • identification verification details;
  • financial details; and
  • other information required to assess your knowledge and experience in the investment field, financial situation as well as investment objectives.

3.3. If you give us false or inaccurate information, either directly or through an agent, and we suspect or identify fraud, we will record this. In addition, we may search at fraud prevention agencies for information on you as part of our due diligence to ensure that we comply with ‘know your customer’ regulations and anti-money laundering legislation.

3.4. We may retain copies of any correspondence you send us, details of your registration history and any materials you post on the Website.

4. What do we do with the information we collect from Guests?

4.1. The main reason we use this information is to provide you with both an improved website experience and details about our services.

4.2. We (or third party data processors, agents and subcontractors acting on our behalf) may also use the information:

  • to enrich your experience and interaction with the Website by allowing you to store your details so that your preferences are retained when you revisit the Website;
  • to analyse site usage and improve our services;
  • to deliver to you any administrative notices, alerts and communications relevant to your use of the services; and
  • to contact you from time to time to inform you about new features, to troubleshoot problems, and to protect you against fraud or other criminal activity.

5. What do we do with the information we collect from Investors?

5.1. We collect information from our Investors for the purposes of contract initiation, performance and termination as well as provision of our services.

5.2. We may use this information in particular:

  • for the administration of the discretionary investment management services;
  • for customer service purposes;
  • for regulatory and legal reasons (e.g. anti money laundering);
  • to develop and improve our services;
  • for the marketing of our services (by us and any of our associates);
  • to carry out statistical analysis and market research;
  • for independent audit purposes; and
  • for any other purposes in relation to our contractual relationship with you.

6. Who else do we share your information with?

6.1. Winterflood Services Limited (“Winterflood”) will provide dealing and custody services to Investors who enter into a discretionary investment management agreement with us. We may disclose your personal information to Winterflood (together with any of our associates or third parties performing services on our behalf) for any of the above purposes.

6.2. We may share your personal information with companies and other third parties performing services on our behalf who will only use the information to provide that service. We may also share your personal information with other members of our corporate group, or a purchaser or potential purchaser of our business.

6.3. In some circumstances, we may have to disclose your personal information by law, because a court or the police or other law enforcement agency has asked us for it. This applies in particular to your personal data we may have to disclose as part of our ‘know your customer’ and anti-money laundering process. Apart from that, we will not sell or disclose your data to any third party other than as set out in this Privacy & Cookie Policy.

7. Marketing, Newsletter & Notices

7.1. We will provide you with our newsletter, information on our services and/or other marketing-related notices via email (together “Notices”), if you have provided your prior consent. To this end, we make use of the online mailing service MailChimp. You will receive a confirmation email with regard to your registration. MailChimp enables us to analyse the use of the Notices.

7.2. If you decide at any time that you no longer wish to receive the Notices, please contact us by email at or unsubscribe using the relevant link provided in the individual Notices. We will always give you an opportunity to unsubscribe from receiving any Notices.

8. Your Rights

8.1. You may request details of personal information which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you please contact us by email at Any access request may be subject to a small fee to meet our costs in providing you with details of the information we hold about you.

8.2. If you think any information we have about you is incorrect or incomplete, please email us at as soon as possible. We will correct, delete or update any information as soon as possible.

9. Security and Third Party Content

9.1. We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk.

9.2. The personal data submitted by Investors is safely stored and encrypted in a data centre located in Ireland and, thus, is subject to European data protection standards.

9.3. We may link to other websites which are not within our control. Once you have left our Website, we cannot be responsible for the content of other websites or for the protection and privacy of any information which you provide on these websites. Please note that these websites have their own privacy policies and website terms and conditions.

10. Cookies

10.1. General

  • We use cookies and super cookies (i.e. local storage) (altogether “Cookies”) on our Website which amongst other things, helps us to improve your experience of our Website and to ensure that it performs as you expect it to. The use of any information gathered by Cookies will only be used under the terms of our Privacy & Cookie Policy.
  • Cookies are text files containing small amounts of information, which are downloaded to your computer or mobile device by websites that you visit. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from Cookies. They can improve your experience of using a website, for example, by remembering your preference settings and tracking your use of a website so that it can be improved to meet your needs.

10.2. Types of Cookies

  • We explain below what Cookies we use on our Website, why we use them and whether they are strictly necessary or another type of Cookie i.e. “functionality”, “performance” or “targeting” Cookies.
  • When you first use our Website, all our Cookies will be turned on and you will have seen our alert about our use of Cookies. If you click “OK” or continue to browse the Website, we presume that you are happy for all Cookies to operate.
  • Session Cookies allow website operators to link the actions of a user during a browser session. A browser session starts when you open the browser window and finishes when you close the browser window. Session Cookies are created temporarily. Once you close the browser, all session Cookies are deleted.
  • Persistent Cookies remain on your device between browsing sessions. They are activated each time you visit the Website that created that particular Cookie. For example, where a persistent Cookie is used on a website to remember your log-in details, you will not need to enter those details each time you visit that website.

10.3. What Cookies do we use?

10.3.1. Strictly Necessary
These Cookies are essential to enable you to receive a service on a website. For example, Cookies to operate online shopping baskets, do your internet banking or to comply with the law (e.g. such as to keep your information safe). We would not be able to operate our Website without using the “strictly necessary” Cookies. These include in particular:

  • AWSELB: Cookie ensures continued usability during updates.
  • userToken: Cookie ensures that user stays logged in.
  • visitorId: Cookie needed for onboarding.
  • wordfence_verifiedHuman: Cookie needed to recognise live traffic.

10.3.2. Performance
These Cookies collect information about how visitors use a website, for instance, which pages visitors go to most often and if they get error messages from web pages. These Cookies do not collect information that identifies a visitor; all information collected by these cookies is anonymous. We only use such information to improve our services and our Website.

10.3.3. Functionality & Profile
These Cookies allow the website to remember choices you make (such as your login details) and custom preference settings (e.g. text size). They also enable enhanced, more personal features, e.g. a website may be able to provide you with local weather reports or traffic news by using a Cookie to remember which region you are in. These Cookies are also used to provide services you have asked for such as watching a video. Information collected by “functionality” Cookies may or may not be anonymised, but they cannot track your browsing activity on other websites. The “functionality” Cookies on our Website only collect anonymous information. These Cookies include in particular:

  • onboarding.progress: Cookie ensures better reloading behaviour.
  • register.index: Cookie ensures better reloading behaviour.
  • wpb_af: Cookie recalls FAQs opened.
  • wfvt_1307309461: Cookie groups the pages a user visits into one.

10.3.4. Targeting, Conversion Tracking and Analysis
These Cookies collect information about your browsing habits and actions such as links clicked, mouse movements or any non-sensitive text entered on our Website. This allows us to make advertising relevant to you and your interests and also to improve the usability and customer experience of our Website. These Cookies collect the most information about users and may be placed by third parties who will be sent the information collected. These Cookies include in particular:

  • _gat: Cookie for Google Analytics.
  • _ga: Cookie for Google Analytics.
  • _hjIncludedInSample: Cookie needed for monitoring actions.

Note: You can opt out of Google Anayltics Cookies under You can deactivate the Hotjar Service under

10.4. Blocking and Deleting Cookies

  • You can control how Cookies are placed on your device from within your own browser.
  • If you’ve disabled one or more Cookie categories, we may still use information collected from existing Cookies, but we’ll stop using the disabled Cookies to gather any further information. You can delete existing cookies from your browser.
  • Blocking and deleting Cookies will have a negative impact impact on the usability of our Website. It may as well be that you will not be able use our Website at all.

Updated: 20. June 2017