Legal

This privacy notice aims to give you information on how Yeeld (‘we’/’the firm’) collects, uses, discloses, transfers, stores and processes your information when you use our services, including any data you may provide through your use of our services.
At Yeeld, we understand that your privacy is important. We respect and value the privacy of everyone:
- Who visits www.yeeld.com (the “Site”)
- The Yeeld app
- Uses any of our applications/services through app or website
We only collect and use your Data as described in this Privacy Notice (“Notice”) and as permitted by Data Protection Legislation (UK GDPR).
It is important that you read this privacy notice together with any other privacy notice/statement or fair processing notice we may provide on specific occasions when we are collecting or processing information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
To navigate through our Privacy Notice just click on the links below. Capitalised terms used in this Notice are defined in the Glossary below.
1.1 Who does this privacy notice apply to?
This notice applies to:
- Our service users who access our services such as our website or content anywhere on the web/Yeeld app,participate in our surveys and focus groups and other users;
- Our clients, suppliers and business partners; and
- Other persons who interact with us, when you call us or email us.
This notice applies to you whether you act in your personal capacity or as an employee or agent of an organisation.

Our Site is owned and operated by Yeeld Technologies Limited.
This privacy notice explains how we, Yeeld Technologies Limited, a company registered in England at Level 18 40 Bank Street, Canary Wharf, London, England, E14 5NR (“Yeeld”, “we”, “us”, or “our”) and our affiliated companies Yeeld Financial Services LTD, Yeeld Investments LTD and other brands process your personal data (“you”, “your”) when you use our website, Yeeld app or other services.
For the purposes of the Data Protection Legislation, we are the data controller which means that we are responsible for determining the purposes for which and means of how your Data is Processed.
If you have any concerns about how we Process or protect your Data or would like to contact us about any aspect of this Notice, please get in touch with our Group Data Protection Officer, who oversees our handling of Data, and who can be contacted at compliance@yeeld.com
This Notice should be read together with our cookies policy, and our Site terms of use.

We will collect Data about you from the following sources:
From you (for example, when you create an account, make a payment, tell us about your preferences or respond to our campaigns, communicate with us, or use our Site or Apps);
From usage of our products and services.
From public sources of information such as public records or social media postings;
From providers about your interactions on the Site and from cookies and tracking devices on your devices where you have permitted their use via Yeeld app;
From third parties, advertisers, and other companies. We may also receive information from other parties in accordance with our responsibilities as a regulated financial services business.
We will collect Data about you from the following sources:

When we collect the Data
Type of Data we hold
Details
When you sign up for Yeeld Account
Your personal and contact details
Information including your name, date, place of birth, home address, email address, telephone number, username and password, details of the device you use, copies of your identification documents and any other information you provide to prove your eligibility to use our services, country of residence, tax residency.
When you sign up/use Yeeld’s services
Account information
Information about your account with us, including your login details for our Site, username for Yeeld, details of your bank account(account number, Sort Code, IBAN), unique customer identification, your registration information, payment method information, details of your debit card/credit card including card number, expiry date and CVC (or other debit/credit cards you register with us), marketing preferences, complaints details and any notes added to your account.
When you sign up/use Yeeld’s services
Visual images
Such as videos and photographs of you, your image in photo or video form, and facial scan data extracted from your photo or video (known as ‘biometric data’), to verify your identity during onboarding as part of our Know-Your-Customer (KYC) checks, to authenticate you as an authorised user of our services, or to detect and prevent fraud.
When you sign up/use Yeeld’s services
Financial information
Such as information that allows us to understand your creditworthiness or your payment method, including bank account or payment card details, information you provide when you sign up for wealth and trading products, including details about your employment and salary.
From external sources
Transactions, and account history
We will also receive information about you when you register with us, information about other people (such as a joint account holder, your spouse or family) when we ask you to give us this information to enable us to comply with our obligations under KYC, anti-money laundering and other laws and to assist with fraud monitoring. We collect personal data from third parties or other people, such as credit reference agencies, financial or credit institutions, official registers and databases, as well as joint account holders, fraud prevention agencies and partners who help us to provide our services. This includes your credit record, information about late payments, information to help us check your identity, information about your spouse and family (if applicable in the context of an application for credit that you make) and information relating to your transactions. Sometimes other Yeeld customers may give us information about you. For example, a yeeld customer may tell us that you have behaved inappropriately and provide us with evidence to support their claim.
When you use our website/ social media
Lifestyle and demographic
Such as information available publicly on your social media profile where you connect with or contact us through your social media account.
When you get in touch
Your communications via our Site and Yeeld App
Such as chat conversations via the Site, your recorded telephone conversations with our customer support staff and emails, mobile network and operating system so we can analyse how our app works and fix any problems, IP address and device ID, location if you've authorised tracking, so we can help protect you against fraud, whether your device uses a virtual private network (VPN), a unique device identifier (for example, your device's IMEI number, or the mobile phone number used by the device), mobile network information, your mobile operating system and the type of mobile browser you use, information stored on your device, including if you give us access to contact information from your contacts list, information on transactions and your use of Yeeld’s products including the date, time, amount, currencies, exchange rate, beneficiary details, details of the merchant or ATMs associated with the transaction (including merchants’ and ATMs’ locations), IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received, details of device used to arrange the payment and the payment method used.
When you use our website
How you use the Site
Such as which pages you visit, which content you view and what links and buttons you click. This information may be collected through cookies or similar technologies. For more information, please see our cookie policy.
When you sign up/use Yeeld’s services
General Location information
The device or computer you use to access Yeeld App will provide us with your IP address. The IP address tells us which city, county or country you are accessing the Site from but does not give us detailed information about your location.
When you sign up/use Yeeld’s services
Device and other technical information
Such as the unique device identifier and other information about the device’s hardware and software.
When you sign up/use Yeeld’s services
Advertising and direct marketing preferences and responses
Such as your interaction with offers and competitions, including any requests to stop receiving marketing communications. This information may be collected through cookies or similar technologies. For more information, please see our cookie policy.
When you sign up/use Yeeld’s services
Sensitive Information
We may also Process Data about you that is sensitive in order to meet our legal and regulatory obligations and to protect our business. This includes Data as required by the Financial Conduct Authority (FCA), the Anti-Money Laundering Regulations and the Proceeds of Crime Act and otherwise any other information to fulfil our legal and regulatory obligations as a regulated financial services business.

Our legal basis for using your personal data will be one of the following:
Legal Obligations
We need to collect and store your personal data for Anti-Money Laundering, Counter-terrorist financing and anti-proliferation financing purpose to comply with wider law and regulations
Executing contracts and agreements
In order to provide our services and execute contractual agreements, we need to collect certain personal data
Legitimate interests
We have legitimate reasons to collect and use your personal data. This is checked to be reasonable and balanced against your individual rights
Public Interest
We process your personal and sensitive personal data to adhere to government regulations, with law enforcement and to support you if it’s necessary to protect your economic well-being and prevent or detect unlawful acts
Consent
Where you've agreed to us collecting your personal data, or sensitive personal data, for example when you tick a box to indicate you’re happy for us to use your personal data in a certain way.
How do we use your data?
We use your Data in the following ways, and for the following reasons:

What we use your Data for
The basis on which we can use your Data
To register you as a new user on the app.
We need to Process this information to meet our contractual obligations.
To allow you to use our services (including managing your payments).
We need to Process this information to meet our contractual obligations and to comply with our legal and regulatory obligations.
To communicate with you about updates to the app, our services, and any changes to our terms and conditions or Privacy Notice.
We need to Process this Data to meet our contractual obligations; to comply with our legal and regulatory obligations; and it is in our legitimate business interests to keep accurate records.
To receive feedback from you on our products and services.
We need to Process this Data to meet our contractual obligations and it is in our legitimate business interests to understand how we can improve our products and services. You do not have to provide us with this information.
To run our promotional events such as competitions and offers which may be of interest to you.We may send you marketing material about our offers and events via email or text. You may opt- out of direct marketing at any time (see below).
We need to Process this information to meet our contractual obligations.We need to Process this Data as it is in our legitimate business interests to provide you with a personalised experience when you use our services. Where necessary, we Process this Data based on your consent.
To provide customer support services.
It is in our legitimate business interests to respond to any communications we receive from you. If you do not wish to provide us with this information, we may not be able to respond fully to your queries.
To train our staff (for example our call staff).
It is in our legitimate business interests to provide you with a helpful service.
To maintain and administer our Site and App.
It is in our legitimate business interests to maintain our IT services and network security, to maintain our system; and we need to Process this information to comply with our legal and regulatory obligations.
To improve our app, products and services, and experiences, such as by understanding analytics.
It is in our legitimate business interests to better understand your preferences, update our app and develop our business strategy.
To comply with our legal and regulatory obligations as a financial services business. This may involve verifying your identity and age.
We need to process this information to comply with our legal and regulatory obligations and it is in our legitimate business interests as well as public interests to prevent fraud and illegal activities on our app.
To protect our business from money laundering, terrorist financing and other illegal activities. We may identify you electronically using technology such as cookies.
We need to Process this information to comply with our legal and regulatory obligations under financial services, anti- money laundering, anti- fraud, and anti- terrorism laws. We also Process this information in the public interest and it is in our legitimate business interests to protect our business from any illegal or abusive use of our Site.
To provide you with advertising which is relevant to you, and to understand your advertising preferences.
It is in our legitimate business interests to understand how you use our Site and how we should develop our marketing strategy.
In relation to legal action, or when acquiring or selling a business.
It is in our legitimate business interest to be able to protect ourselves through legal action and todevelop the business through acquiring or selling parts of our business.
To provide location-based services.
It is our legitimate interests with your consent (to track you when location services are on).

In some cases, we may share your Data with third parties in order to support your needs, provide you with services, or comply with our legal obligations. We may also share Data with third parties if it is in the public interest or the sharing is in our legitimate interest or the legitimate interest of another organisation.
The other organisations we may share your Data with are typically:
- Members of the Yeeld technologies LTD (Yeeld group) for the purposes in section 4
- Third-party suppliers and service providers for the purposes identified above – in particular, we work with platform services (to provide financial services and account management functions), cloud providers (to host the Site), affiliate platform services, business intelligence and analytics platform provider, investment services provider, companies that help us with functional analytics, our insurance providers and other third companies that give us benefits, customer support software services, data storage services, payment service providers, know-your-customer and anti-money laundering services as well as enhanced due diligence and anti-fraud services, financial services regulators (such as the FCA).
- Business partners and other organisations to help us meet our contractual and regulatory obligations, including audit, legal and compliance services.
- Affiliates and third parties whom you have opted out of marketing communications with, have been barred or have self-excluded so that we can ensure that you do not receive unsolicited promotional material.
- Identity verification and fraud prevention agencies such as other financial services businesses, banks, credit card companies and similar agencies which investigate and prevent underage, fraudulent, criminal or suspicious activity, or any other behaviour we are legally required to investigate. We will also pass on your information if we have reason to believe you have undertaken such activity.
- Analytics and search engine providers and other selected organisations which provide us with feedback about our Site or Apps and aid us in improving their optimisation.
- Statutory authorities when we are required to comply with a request for information, a court order to disclose your Data, a regulatory investigation from a relevant governmental or financial or regulatory authority, our legal obligations including our requirement to report suspicious behaviour.
- Regulator, law enforcement or fraud prevention agencies as well as legal professionals, courts and other adjudication services to investigate any actual or suspected criminal activity.
We may also share your Data with third parties:
- If we consider selling or acquiring businesses or assets, in which case we will share your Data with the counterparty.
- If Yeeld, or any of its group companies, becomes insolvent (i.e., becomes subject to administration or liquidation processes).
- If we, or substantially all of our assets, are acquired by a non-Yeeld Group entity. If we need to enforce our terms and conditions.
- To protect our safety, rights or property, or the safety, rights or property of our customers, staff and others by sharing information with other companies and organisations such as the local police.
- Where we are required by law, we may share your Data with regulators or other financial services organisations.
Our Partners who help to provide our services: Wealthkernel, Caxton.

We will not keep your Data for longer than is required for the purposes for which we collected it, including for the purposes of satisfying any legal requirements. The length of time for which we retain your Data will depend on what we are using it for as set out in this Notice, the nature of the Data and how sensitive it is. For example, we will keep your email address while dealing with your enquiries but, even when you unsubscribe, we are required to continue to retain your email address to ensure that we do not send you any email communications in the future and for our know-your- customer (“KYC”) purposes.
Please note, however, that we may be subject to legal and regulatory requirements to keep your Data for a longer period. We may also extend the retention times where the Data is needed to investigate a crime, handle a claim or resolve a complaint. As a general rule, we keep your Data based on the criteria below:

Type of Data
Typical Retention Time
Information
Marketing consents
Until you no longer consent
If you withdraw consent, we will keep this information on a ‘suppression list’ so we don’t contact you
Customer call recordings
[24] Months
Extended retention may be applied on a case by case basis
Customer Data
Seven years from the date your account is closed (As long as necessary for legitimate reasons)
We will only continue to retain this Data where this is:
- Legally required under financial services regulations or tax legislation or other regulations; or
- Required to exercise or defend our legal rights

We primarily store and Process our Account data within the UK. We may store the data we collect from you outside the UK, or transfer it to organisations outside the UK. However, if we transfer your Data outside the UK, we ensure a similar degree of protection is afforded to it to safeguard your Data in accordance with Data Protection Legislation, which can include by:
- (i) ensuring that your Data is only processed in countries which provide adequate data protection laws (in accordance with the Data Protection Legislation);
- (ii) requiring recipients to sign up to strong contractual commitments that ensure the protection of your Personal Data
- (iii) taking any other measures that comply with Data Protection Legislation.

We understand that protecting and managing your personal data is of utmost importance. Any personal data we collect, process will be dealt with carefully and securely. To maintain the confidentiality, availability and integrity of your personal data and to ensure your data is not improperly used or disclosed, we have put in detailed information security and data protection policies which our employees, partners and all stakeholders are required to follow when they handle your personal data.
Furthermore, we regularly train our employees on data protection and information security training. Personal data is stored on secure computer systems with access management controls in place to limit physical, system and information access to only authorised employees. Yeeld has strict policies in place that control how we share your personal data with other companies. Before sharing personal data with any company, we thoroughly:
- vet the company in advance
- assess the security controls the company has in place to protect your personal data.
We have separate information security policies in place that demonstrate how data will be kept secure from unauthorised access.
While the nature of the internet means that the transmission of information may not be totally secure, we have implemented security measures to prevent your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where you use a password to access certain services or features of Yeeld app, please keep this confidential and do not share it with anyone.Unfortunately, we cannot guarantee the complete security of the information transmitted via the internet. While we have implemented security measures, any transmission is at your own risk.

You can tell us whether or not you wish to be contacted for marketing purposes and, if so, how we can contact you. We will obtain this information from you when we first collect your Data and we may ask you what kind of communication you would like to receive from us.
You can opt-out of receiving marketing communications from us at any time by following the instructions below:
- Email marketing: to opt-out from emails, use the unsubscribe link provided within any email you receive or manage your preferences by emailing compliance@yeeld.com or by telephoning 02080505813.
- SMS Marketing: to opt-out from SMS, you can use the STOP code provided in any SMS you receive or manage your preferences by emailing compliance@yeeld.com or by telephoning 02080505813.
- Call Marketing: to opt-out of being contacted by telephone for marketing purposes, you can manage your preferences by emailing compliance@yeeld.com or by telephoning 02080505813.
- Post Marketing: to opt-out of receiving marketing by post, you can manage your preferences by emailing compliance@yeeld.com or by telephoning 02080505813.
- Push notifications: to opt-out of receiving push notifications, you can disable push notifications on your device or browser settings.
Please be aware it may take up to 28 days for your request to take effect. Please note you will still receive other important information about our product and services.

Your rights
How to exercise your rights
Right to access and receive a copy of the Data we hold about you./ ask for a copy of your personal data in a portable (machine-readable) format or make us send it to someone else;
It is generally free for you to request access to your Data by contacting our data protection representative by

emailing compliance@yeeld.com or by telephoning 02080505813.

You have the right to request:
- Whether your personal data is being processed
- The purpose of the processing
- The categories of personal data being processed
- The purpose of the processing
- How long it will be stored
- The existence of the right to request rectification or erasure of personal data or restriction of processing of personal data
- The right to lodge a complaint with the ICO
- Where the personal data are not collected from you directly, any available information as to their source;
- The existence of automated decision- making, including profiling.
If your request is repetitive or excessive, we may refuse to comply or we may charge you a fee.
Right to correct any inaccurate Data we hold about you.
You can amend, correct, delete or edit your Data if you wish to, please contact our customer support team by telephoning 02080505813.
Right to require us to delete your Data if (for example): (i) we no longer need the Data for the purpose we originally collected it for; (ii) we only collected it with your consent, and you now withdraw your consent; or (iii) you object to how we are Processing your Data.
You can request erasure of your Data by contacting our customer support team by telephoning 02080505813.
This process is not reversible and subject to approval.
Right to request that we restrict the Processing of your Data if (for example): (i) you believe that the Data we hold on you is inaccurate; (ii) you have the right to request that we erase your Data but would prefer us to restrict our Processing instead; or (iii) we no longer need the Data for the purpose we originally collected it for but you require the Data for legal actions.
You can request the restriction of Processing of your Data by contacting our customer support team by telephoning 02080505813. Once you have requested this you can change your mind at any time by contacting us again. Your account will not be accessible while the restriction is in place.
Right to request a copy of the Data we hold on you in a structured, commonly used and machine-readable format. You can also request that we transfer this to a third party on your request. Please note that this right may not apply to all of your Data.
In some circumstances, you can request the transfer of your Data to a third party by email to compliance@yeeld.com The request must include which Data you would like to be transferred, to whom it should be transferred and by which method.
Right to restrict our processing of your personal Data, including for marketing purposes. Please note that in some cases, we may demonstrate that we have legitimate grounds to Process your information which overrides this right.
You can object to Processing of your Data by contacting our customer support team by telephoning 02080505813 Once you have objected you can change your mind at any time by contacting us again. Your account will not be accessible while the restriction is in place.
Right to not be subject to a decision based solely on an automated process, such as profiling, which results in you being significantly affected or produces legal effects concerning you.
You can exercise this right by contacting our customer support team by telephoning 02080505813.
Right to withdraw your consent where we only Process your Data based on your consent. You can withdraw your consent to receive marketing communications from us at any time and for free.
To exercise your right to withdraw your consent to receive marketing communications please see section 10 above.

We may, from time to time, change or update this Privacy Notice in line with legal requirements or if our business changes. All changes to this Privacy Notice will be published on this page of the Site.
Each change will become effective on publication. We recommend that you revisit and read this Privacy Notice regularly to ensure that you are up-to-date with the current terms. If we change the way we use your personal data, we’ll update this notice and, if appropriate, let you know by email, through the Yeeld app or through our website.
This Notice was last reviewed and updated in October 2024.

Yeeld may collect data about you even if you are not a Yeeld customer. This might be if you use our website, pay or get paid by a Yeeld customer, or are named as a beneficiary for a Yeeld customer.
The information we might collect and hold about you may include:
- Your name
- Your contact details
- ID documents such as driving licence, passport
- Payment details including card details
- Your transaction history
- Social media details
We will use your data for contractual purposes to facilitate payments, send receipts, answer your queries, to identify and verify you when you sign up or get in touch, check your records against fraud prevention agencies and prevent illegal activities. Also, we might need to use your data for legitimate interests which do not override your rights. We also sometimes make automated decisions to take certain actions such as freezing transactions, fraud detection or to market our products and services. If you want us to review an automated decision please email compliance@yeeld.com.
We may share your data with our partners if it’s necessary (please refer to section 5), social media companies, law enforcement agencies and other Yeeld’s sister companies. We will keep you information for 6 years or as long as necessary for regulatory and legal purposes.

Term
What this means
Data
Information relating to an identifiable person, who can be directly or indirectly identified in particular by reference to an identifier, or which is otherwise defined as ‘Personal Data’ under Data Protection Legislation.
Data Protection Legislation
Data Protection Act 2018 (UK GDPR), EU General Data Protection Regulation 2018 (GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003, and any other applicable laws relating to the protection of Data.
Process, Processing or Processed
Accessing, collecting, obtaining, recording, holding, disclosing, using, altering, deleting, erasing or destroying Data, or carrying out any operation(s) on the Data or as otherwise defined under applicable Data Protection Legislation.

Cookies are small text files placed on your device when you visit websites. Each cookie includes the website name and a unique ID. At Yeeld, we use cookies and similar technologies to collect information about how visitors interact with our website — such as which pages they view and which buttons they click.
This data helps us understand what people like about our website and how we can improve the experience for others. For example, we may see which content is most popular with visitors and optimise accordingly.

Most of the cookies we use are persistent, meaning they remain on your device until they expire or are deleted. Others are session cookies, which are erased when you close your browser.
Below are the categories of cookies we use:
- Necessary cookies
  - These are essential for our website to function properly.
  - They help us detect server issues and store your cookie preferences.
  - We do not need your consent to use these.
- Preferences cookies
  - These remember your settings (e.g., country or language) to improve your browsing experience.
- Analytics cookies
  - These help us count visitors and understand how they interact with the site.
  - This data helps improve our content and design.
- Advertising cookies
  - These build a profile of your interests and show you relevant adverts.
  - We may share this data with trusted partners like Google and Meta.

Please read this Agreement carefully before requesting a Wallet and a Card. This Agreement becomes effective and binding on you when you click to accept it when you apply for a Wallet and a Card. This Agreement will continue until either you or we end it, in accordance with the terms set out below.
The Yeeld Connect Terms and Conditions shall also govern and apply in full to the use of Yeeld Companion. By accessing or using Yeeld Companion Wallet, you acknowledge and agree that you are bound by the terms set forth in the Yeeld Connect Terms and Conditions, in addition to any specific terms that may be applicable to these terms and conditions.
This Agreement includes the Fee & Limits Schedule at the end of this document and constitutes a binding agreement between you and Transact Payments Limited.

Account Information Service Provider
- a third-party payment service provider which is authorised by a financial regulator to provide online account information services and which, if you allow it, will be able to access certain online account information in the Wallet, such as the payments you make and receive;
Account Information Service Provider
- the mobile application provided by Yeeld that allows you to access the Wallet and take actions, such as making payments, viewing your Transaction history, blocking the Card and raising queries with Customer Services;
Applicable Law
- any law (including but not limited to, any local law of the jurisdictions into which the Wallet and/or Card are provided and the Program is operated), statute, statutory instrument, act, regulation, rule, order, supervisory guidance, policy, instruction or requirement stipulated by an applicable Regulatory Authority, or interpretation published by any Regulatory Authority, any order issued by a court which has jurisdiction over you, us Payload, Inc. or Yeeld, or any rule or requirement set by Visa related to the Card or Wallet and/or any of the services to be provided under this Agreement or such other rule that we consider to be valid and as amended from time to time;
Available Balance
- the value of unspent funds loaded onto the Wallet and available for you to use;
Business Day
- Monday to Friday, 9am to 5pm CET, excluding bank and public holidays in Gibraltar;
Card
- any Physical Card or Virtual Card which we issue to you in accordance with this Agreement;
Card Transaction
- using the Card to make (i) a payment, or a purchase of goods or services from a Retailer where you pay (in full or in part) with the Card, including where you pay over the internet, by phone or mail order or (ii) a cash withdrawal from an ATM or bank using the Card;
CHAPS
- the Clearing House Automated Payment System, a service which allows organisations to make same-day payments to an account within the UK, within the CHAPS operating days and times;
Co-Brand, Yeeld
- Yeeld Financial Services Ltd incorporated in England and Wales with company registration number 15776510 and registered office address at Level 18 40 Bank Street, Canary Wharf, London, England, E14 5NR;
Customer Services
- the contact centre for dealing with queries about the Wallet and Card. You can contact Customer Services by:
  - (a)
    calling 02080505813 (your network provider may charge a fee for calling this number);
  - (b)
    e-mailing support@yeeld.com from the email address registered to the App; and
  - (c)
    using “chat to us” in-app live chat functionality;
Direct Debit
- a payment collected via the UK Direct Debit scheme from or to your Wallet;
Expiry Date
- - (a)
    for Physical Cards: the expiry date shown on the Card.
  - (b)
    for Virtual Cards: the expiry date which can be found in the ‘Card’ section of the App;
Faster Payments
- a service which allows you to make and receive electronic payments in the UK. The payment is received by the recipient organisation or bank within 2 hours, as long as the receiving organisation or bank is part of the Faster Payments Scheme;
Fee
- any fee payable by you as referenced in the Fees & Limits Schedule.
Fee & Limits Schedule
- the schedule contained in this Agreement;
KYC
- means “Know Your Customer” and refers to the ways in which we are required to check your Personal Details and identity;
Mastercard
- Mastercard Europe sprl, the payment network applicable to the Card;
Payment Initiation Services Provider
- a third-party payment service provider which is authorised by a financial regulator to provide an online service to make a payment from your Wallet at your request;
Personal Details/ Personal Data
- the registered personal identity details that are collected from you relating to your use of the Wallet, Card and App including (but not limited to) your: name, date of birth, home address, email address and telephone (landline and/or mobile) number. Full details of the Personal Data which we process are set out in our Privacy Policy;
Physical Card
- a physical/plastic Card that you can use to carry out Transactions;
PIN
- a Personal Identification Number; that is, the security number which we give to you to use with the Card;
Program
- the marketing, processing, administration, supervision, maintenance, servicing, authorisation or usage of the Card and Wallet and any other payment services established in accordance with this Agreement;
Program Manager, Payload
- Payload Ltd., incorporated and registered in England and Wales with registered office at Epworth House, 25 City Road, London EC1Y 1AA; or Co-Brand on its behalf;
Regulatory Authority
- Mastercard and/or any regulator or agency (for example, the Gibraltar Financial Services Commission, which is the body which grants our e-money licence and supervises our actions) which has authority over us or Payload or Yeeld in relation to the Card, Wallet, Program or any services provided under this Agreement;
Retailer
- a retailer or any other person which accepts e-money;
Third-Party Provider/TPP
- an Account Information Service Provider or a Payment Initiation Service Provider;
Transaction
- any debit, credit or adjustment to a Wallet that affects the balance of funds held in it including a Card Transaction;
Username and Password
- a set of personal codes selected by you in order to access the App;
Virtual Card
- a non-physical Card that you can use to carry out Card Transactions. When we refer to a Physical Card in this Agreement, we are referring only to the Physical Card and not the Virtual Card;
Wallet
- the electronic money account provided to you by TPL and opened in accordance with this Agreement;
Website
- www.yeeld.com
we, us or our
- Transact Payments Limited (“TPL”), a company incorporated in Gibraltar with registered address at 6.20 World Trade Center, 6 Bayside Road, Gibraltar, GX11 1AA, company registration number 108217 and which is authorised by the Gibraltar Financial Services Commission as an electronic money institution; and
you or your
- You, the person who has entered into this Agreement with us by applying to open a Wallet and be issued with a Card in accordance with this Agreement.

1.2.1
The Wallet is an electronic money account provided by us in accordance with our licence granted by the Gibraltar Financial Services Commission. You must use the Wallet in accordance with this Agreement.
1.2.2
The Card is issued by us in accordance with our licence from Mastercard and you must use the Card in accordance with this Agreement.
1.2.3
You are not permitted to re-sell the Card.
1.2.4
You can download or print the latest version of this Agreement at any time from the App and/or Website and/or request a paper copy from Customer Services
1.2.5
If you do not agree with or accept any of these terms and conditions, you should close the Wallet, cancel the Card and stop using the App.
1.2.6
Your funds are safeguarded in accordance with Applicable Law to ensure they remain protected and are not affected in the event of our insolvency.

2.1
To apply for, and use, a Wallet and Card you must be at least 18 and resident in the United Kingdom.
2.2
You may apply via the App (downloaded via Google Play or the Apple App Store). We may require you to provide information/documentary evidence to prove your identity and address and/or we may carry out electronic identification verification checks on you.
2.3
Once we have been able to successfully complete KYC, you will have to insert card details on the App once you receive the card and you will be able to use the Wallet and Card once you verify your card details through the app.
2.4
You are only allowed to hold one Wallet where your Available Balance is located.(Except virtual cards) If we discover that you do have more than one Wallet, we may block the Card and Wallet and terminate this Agreement.

3.1
When you buy goods and services online, some websites may require you to enter your Personal Details. If this happens, you should enter your up-to-date Personal Details.
3.2
You must notify Yeeld of any change in your Personal Details as soon as possible by contacting Customer Services or updating the details in the App. You will have to pay for any loss that happens directly as a result of any delay in telling us that your Personal Details have changed or if you have not told us because you’ve been grossly negligent or committed fraud. We will need to verify your new Personal Details and may request relevant KYC information/documents from you.
3.3
We, or Payload or Yeeld, reserve the right at any time to satisfy ourselves that your Personal Details are correct (for example, by requesting relevant original documents) including so that we can prevent fraud and/or money laundering. You also agree to authorise us and Program Manager to undertake electronic identity verification checks on you either directly ourselves or using relevant third-party companies at the time when you apply for a Wallet or Card or at any time in the future

4.1
You can use the Wallet subject to the Fees which you can find in the Fees & Limits Schedule. The Fees will be deducted from the Available Balance as they are charged to you.
4.2
You can receive funds into the Wallet by electronic funds transfer using CHAPS, Faster Payments and any other payment type as notified by us to you from time to time. We will credit the Wallet when we receive the funds.
4.3
The Wallet can also receive internal transfers from other Wallets owned or controlled by you, which apply instantly.
4.4
The Wallet will not be credited if:
- - (a)
    The Wallet is suspended, restricted or terminated;
  - (b)
    The sender has provided incorrect/invalid Wallet details for the Wallet; or
  - (c)
    We suspect the transfer to be fraudulent.
4.5
While Penny AI uses advanced algorithms to provide tailored insights, the accuracy of its recommendations depends on the completeness and accuracy of the data you provide. Yeeld does not guarantee the accuracy or suitability of Penny AI’s outputs and is not responsible for decisions made based on them.
4.6
In order to manage our risk, particularly with respect to money laundering, fraud or security concerns, we also apply internal controls, including limits, to certain types of payment. We change these as necessary but for security purposes, we may or may not disclose them to you.
4.7
You can send funds from the Wallet to external bank accounts using Faster Payments, CHAPS and other methods which we notify you about from time to time.
4.8
If for any reason whatsoever a Transaction is carried out (including a Card Transaction), but the amount is greater than the Available Balance, you must pay us the difference immediately. If you don’t pay us after receiving a notification from us, we reserve the right to take all necessary steps to recover the difference, including taking legal action. We may charge the amount of the difference against any funds on the Wallet, including any funds that are loaded at a later date. We may arrange for the Wallet and/or Card to be suspended until we are reimbursed with the difference.
4.9
The Wallet will be terminated if you use it for any illegal purposes, in accordance with clause 10.4(b)iv.
4.10
The Available Balance on the Wallet will not earn any interest.
4.11
You are not permitted to set up Direct Debits from the Wallet.
4.12
Yeeld, or its commercial partners, may provide you with promotional and financial incentives, such as cashbacks, round-ups, auto save and investment tools. Those incentives are not provided by TPL, are not governed by this Agreement and TPL is not responsible or liable for them or for any losses that you may incur when using them. Should you have any queries regarding those incentives, please refer to your contracts with Yeeld, or its group companies or partners, that you can find on the Yeeld Website.

5.1
You can allow a Third-Party Provider (also referred to as a ‘TPP’ or ‘Open Banking Provider’) to have access to the information in the Wallet or to initiate certain Transactions from the Wallet. The TPP must be authorised to provide these services to you, and we recommend that you check their authorisation on their regulator’s register of authorised providers before using them.
5.2
When you use a TPP, you authorise and consent to them accessing the Wallet or making payments from the Wallet on your behalf. Once the TPP properly identifies itself to us, we will treat any instruction from the TPP as if it was an instruction from you. You also consent to us sharing any information (including Personal Data) with the TPP that is reasonably required for them to provide their services to you.
5.3
We may deny a TPP access to the Wallet or to make a payment if we are concerned about unauthorised or fraudulent access by that TPP. If we do block access, we will tell you beforehand or as soon as possible afterwards in a way that we consider the most appropriate. We won’t tell you if Applicable Law prevents us from doing so or if there are valid security reasons for not informing you. We will unblock access to the TPP when the reasons for blocking no longer exist.
5.4
You also have the right to block or withdraw access to the Wallet by the TPP and you should contact Customer Services if you wish to do this.

6.1
You can use the Card subject to the Fees which you can find in the Fees & Limits Schedule. The Fees will be deducted from the Available Balance as they are charged to you.
6.2
The Card is to be used to spend the funds in the Wallet.
6.3
Unless we tell you otherwise, you can use the Card at any Retailer which accepts Mastercard.
6.4
There are certain circumstances when a Retailer may require you to have an Available Balance which is greater than the value of the Card Transaction you wish to make. Retailers may request this as they may need to access more funds than you initially planned to spend for example, when you make hotel or rental car reservations. If this happens, you will not have access to the blocked amount of funds until the Card Transaction is completed or, at the latest, for up to a period of 30 days. We will only block access to the exact amount of funds authorised by you. You will only be charged for the actual and final value of the Transaction.
6.5
You cannot use the Card at Retailers that cannot check that you have sufficient Available Balance for the Card Transaction (for example, Card Transactions made on trains, ships, some in-flight purchases and tollbooths which are not online).
6.6
We accept no liability if a Retailer refuses to accept payment using the Card. It is your responsibility to check the restrictions of each Retailer.
6.7
We do not recommend using a Virtual Card to buy an item over the internet that would require you to show a Physical Card in order to collect that item. For example, certain theatre ticket purchases, hotel stays, car rentals, and online purchases picked up in person.
6.8
Depending on the type and location of the ATM and the Card settings, you may not be able to withdraw cash using a Virtual Card.
6.9
You must not use the Card for any illegal purposes.
6.10
Yeeld, or its commercial partners, may provide you with promotional and financial incentives, such as cashbacks, round-ups, auto save and investment tools. Those incentives are not provided by TPL, are not governed by this Agreement and TPL is not responsible or liable for them or for any losses that you may incur when using them. Should you have any queries regarding those incentives, please refer to your contracts with Yeeld, or its group companies or partners, that you can find on the Yeeld Website.

7.1
You must give your consent to each Transaction by a) entering your PIN or other security information; b) providing the Card details and/or providing any other details personal to you and/or the Card; or c) authorising a TPP to initiate a Transaction. Once you have given such consent to the Transaction, we will consider it to be authorised by you.
7.2
When you make a Transaction, we consider it to be received when it is received by our processing partner. If a Transaction order is received after 4pm on a Business Day, then it will be considered to have been received on the next Business Day.
7.3
Once a Transaction has been authorised by you and received by us, it cannot be reversed.
7.4
Your ability to use or access the Wallet or Card may occasionally be interrupted, for example, if Program Manager or any third-party service providers need to carry out maintenance on their systems or websites. Please contact Customer Services should you experience any problems using the Wallet or Card and these will be resolved as soon as possible.

8.1
You will need a PIN to make payments at a Retailer or to withdraw cash with the Card. Your PIN will be available to you in the App, under “Cards” and “View PIN”.
9.2
If you forget your PIN, you can retrieve it from the App, under “Cards”, “View PIN”. For further assistance with any PIN-related queries, please contact Customer Services.
8.3
You must not give the PIN to any other person or allow any other person to use the Card, Wallet, App or device that you use to make Transactions.
8.4
You are responsible for the Card, Wallet, device, App and any related passwords, logins or other security details (we will refer to all of these as “Security Details” in the rest of this clause 9) and you must take all possible measures to keep them safe and entirely confidential. Examples of these measures include (but are not limited to):
- - (a)
    Never letting any other person use your Security Details;
  - (b)
    Never writing your Security Details down in a way that allows anyone else to recognise them;
  - (c)
    Never writing your Security Details on the Card or on anything you usually keep with the Card; and
  - (d)
    Keeping your Security Details secret at all times for example, by not using your PIN or password if anyone else is watching.
8.5
If you don’t keep your Security Details safe, you may not be able to claim any losses if we can show that you have intentionally failed to keep the information safe or you have acted fraudulently, with unreasonable delay or with gross negligence. In all other circumstances, the maximum amount that you will be required to pay will be £35.
8.6
If you believe that someone else knows any of your Security Details, you must notify us by contacting Customer Services immediately.
8.7
if we suspect or believe that there may be a security threat or a threat of fraud to the Wallet or Card, Program Manager will notify you securely via email, SMS and/or push notification via Yeeld app.
8.8
Once your Physical Card has expired or if it is found after you have reported it as lost or stolen, you must destroy it by cutting it in two through the magnetic strip.

9.1
Unless this Agreement is terminated by you or by us, it shall remain in force.
9.2
When this Agreement is terminated, the Wallet and Card will be closed, and you are not permitted to use either of them.
9.3
Termination by You
- - (a)
    You may close the Wallet or Card at any time by contacting Customer Services. You may choose to close the Card and still use the Wallet (in which case only the provisions in this Agreement which relate to the Wallet will apply). You may not use the Card without the Wallet. Once the Wallet is closed, this Agreement will be terminated.
  - (b)
    If any further Transactions are found to have been made or charges or Fees incurred using the Wallet or Card or if we receive a reversal of any Transaction which added funds to the Available Balance, we will notify you of the amount and you must immediately repay it to us.
9.4
Termination or Suspension by Us
- - (a)
    We, or Program Manager for us, may terminate this Agreement at any time by giving you two months’ advance notice, which will be sent to the email address that you have provided to us.
  - (b)
    We, or Program Manager for us, can suspend the Wallet or Card, restrict their functionality or terminate this Agreement at any time with immediate effect if:
- - (i)
    you haven’t given us the information we need or we believe that any of the information that you have provided to us was incorrect or false; or
  - (ii)
    you do not repay money that you owe to us; or
  - (iii)
    you fail to provide the Personal Data necessary for us to comply with our legal or regulatory obligations and to fulfil this Agreement; or
  - (iv)
    we reasonably suspect that the security of the Card or Wallet has been compromised or that you, or any third party, have used, or intend to use the Card or Wallet in a grossly negligent way or for fraudulent or other illegal purposes; or
  - (v)
    we believe that your use of the Card or Wallet may result in harm to us or our systems; or
  - (vi)
    we believe that your continued use of the Card or Wallet may damage our reputation; or
  - (vii)
    you become bankrupt; or
  - (viii)
    we are required to do so under Applicable Law or if we believe that your continued use of the Wallet and/or Card may be in breach of Applicable Law; or
  - (ix)
    we cannot process some or all of your Transactions due to the actions of third parties; or
  - (x)
    you have breached an important part of this Agreement or have repeatedly breached any term of this Agreement and have failed to resolve it in a timely manner.
9.5
If we do suspend, restrict or terminate the Wallet or Card then, if we are legally allowed to, we or Program Manager will notify you in advance or as soon as possible afterwards. We may advise anyone involved in the Transaction if a suspension has taken place. If possible, we or Program Manager will provide the reasons for the suspension, restriction, termination or refusal to execute a Transaction. If we suspend or block your Card or Wallet, we will unblock it as soon as the reasons for blocking it no longer exist.
9.6
You can redeem your Available Balance by withdrawing it at an ATM at any time while your Wallet is open. Once your Wallet is closed, and subject to any legal obligations that we have to comply with, you will be able to gain access to the funds in the Wallet at any time within six years from the date that this Agreement ends.
9.7
If your Wallet is closed and you request that we send the Available Balance back to you, we may require that the funds are sent to an account in your name. We may also require you to provide us with KYC information and/or documents so that we can check your identity. We may charge a Redemption Fee if you request your Available Balance before, or at least 12 months after, this Agreement ends. If we do charge a Redemption Fee, it is set out in the Fees & Limits Schedule.
9.8
If you owe us any funds or Fees when you request your Available Balance, we shall have the absolute right to deduct those funds of Fees from the funds held in your Wallet.

10.1
You are responsible for protecting the Wallet and Card as if they were cash in a physical wallet – if the Available Balance is lost or stolen, you may lose some or all of the money on the Wallet unless you contact us as specified in this clause.
10.2
If you know or suspect that someone has gained unauthorised access to the Wallet, if you think the Card has been lost or stolen or if you think that a Transaction has not been carried out correctly, you must immediately contact customer support via in-app chat functionality or email at support@yeeld.com. You must also immediately freeze the Card in the App.
10.3
If the Card was lost, stolen or used by someone without your permission and you haven’t reported it to us when you became aware of it, you may be responsible for all of the losses. If our investigations show that you authorised a Transaction that you’re disputing or that you acted fraudulently or that you negligently or intentionally breached the terms of this Agreement (for example, if you showed someone your PIN and they made a payment with your Card without you knowing about it), we may not refund you the amount that was spent.
10.4
Once you report a loss, theft or unauthorised use of the Card or Wallet, we will block them so that they can no longer be used.
10.5
Replacement Cards will be sent to the most recent address you have provided and [will be subject to a Fee, as set out in the Fees & Limits Schedule].
10.6
You agree to cooperate with our agents, any supervisory authority, the police and us if the Card or Wallet is lost, stolen or if we suspect that someone has used it fraudulently.
10.7
If you think that a Transaction has been made that you didn’t authorise or you think that it was incorrect, you must tell us as soon as possible, and no later than 13 months after the Transaction date, and we will refund the amount immediately. We won’t refund it if we believe that the incident may have been caused by a breach of this Agreement, through gross negligence or if we have reasonable grounds to suspect fraud.
10.8
If you don’t think we’ve carried out a Transaction correctly, we will immediately try to trace the Transaction and will notify you of the outcome. We will not charge you for doing this. If we are liable for the Transaction, we will refund the amount as soon as we can, together with the amount of any fees which may have been charged to you.
10.9
If a Transaction that you’re disputing was initiated by a TPP, the TPP must prove that the Transaction was authenticated, accurately recorded and not affected by a fault linked to its payment initiation service.
10.10
If a Transaction that was made within the UK arrived later than it should have, according to the terms of this Agreement, you may ask us to contact the receiving bank to ask them to treat it as if it was made on time.
10.11
If you ask us to investigate a Transaction which is initiated by a Payee (for example, a recurring payment which you have authorised) and the exact Transaction amount was not specified when you authorised the payment and the amount was more than you could have reasonably expected, taking into account your previous spending pattern, the terms of this Agreement and the relevant circumstances of the case, we will refund that amount.
10.12
We won’t refund it if the amount relates to currency exchange fluctuations, if you have given your consent to execute the Transaction directly to us or if information on the Transaction was made available in an agreed manner to you at least 4 weeks before the due date of the Transaction.
10.13
We will only provide a refund if you request it from us within 8 weeks of the date on which it was debited.
10.14
If a Transaction is paid into the Wallet that should not have been, we will, where possible, immediately send the funds back to the account or bank acting for the person who sent the payment. If this happens, you agree to return the funds to us and to provide the help we need to recover the amount from you. If we cannot recover the funds, we are required to provide sufficient details about you and the incorrect payment to the bank or institution that sent the payment so that they can recover the funds.

11.1
If you dispute a Card Transaction that you have authorised, and which has been processed on the Card, you should settle this with the person you bought the goods or services from; we are not responsible for the quality, safety, legality or any other aspect of goods or services purchased with the Card.
11.2
If the dispute cannot be resolved you should contact us at Customer Services, and we will try to help you to resolve it.
11.3
If you have reason to believe that a Card Transaction was carried out without your consent or in error, you may ask Program Manager to investigate it. If an investigation occurs, the disputed amount will be unavailable to spend until our investigation is complete and if we receive information that proves the Card Transaction was genuine, this will be deducted from your Available Balance and we may charge you an investigation fee, subject to the Fees & Limits Schedule. If you do not have sufficient Available Balance, you must repay us the amount immediately when we ask for it.

12.1
You can receive payments into the Wallet and make payments out of the Wallet in Pounds Sterling (GBP) only.
12.2
If you use the Card in a currency other than the currency of the Card (we will refer to this amount in this clause as the “Foreign Currency Transaction”), we will use an exchange rate set by Mastercard to convert the amount to the currency of your Card and we will deduct it from your Available Balance. For example, if the currency of your Card is Euros and you buy a product in Pounds Sterling, we will convert the Pounds to Euros and then deduct the Euro amount from your Available Balance.
12.3
You may also be charged a Currency Conversion Fee as set out in the Fees & Limits Schedule below.
12.4
You can compare charges for currency conversion with other Cards’ charges by checking the real-time percentage difference between the amount that will be charged on the Card for a Foreign Currency Transaction (which consists of the mark-up applied by Mastercard as well as any other charges) and the latest available euro foreign exchange rates issued by the European Central Bank. You can see this information on the Website before you make a Foreign Currency Transaction.
12.5
Exchange rates can go up and down quickly and they may change between the time you make a Transaction and the time it is deducted from your Account/Available Balance. You agree that any change to the exchange rate may be applied immediately and without us giving you any notice.

13.1
We shall not be liable for:
- - (a)
    any loss which occurs from anything which is directly or indirectly beyond our control. Examples of this include: if there aren’t enough funds in an ATM, if the ATM network fails, if you can’t withdraw funds due to the ATM operator setting limits on funds that can be withdrawn or if their data processing system doesn’t work properly;
  - (b)
    any loss of profits, loss of business, or any indirect, consequential, special or punitive losses;
  - (c)
    any loss arising from any use of the Wallet or Card that does not comply with this Agreement;
  - (d)
    any goods or services that you buy with the Card;
  - (e)
    anyone refusing to accept the Card; and vi. any damages that you suffer due to loss, fraud or theft that you have reported to us later than 13 months after the event/debit date.
13.2
If the Card is faulty and this is our fault, our sole responsibility will be to replace the Card.
13.3
If funds are incorrectly deducted from your Available Balance and this is our fault, our sole responsibility will be to pay you the correct amount.
13.4
Nothing in this Agreement shall exclude or limit our liability for death or personal injury resulting from our negligence or fraud.
13.5
The exclusions and limitations set out in this clause will also apply to any of our partners, including Mastercard and other suppliers, contractors, representatives and any of their partners (if any) which may arise in connection with this Agreement.

14.1
If you would like to make a complaint about the Card or Account, please send an email to Program Manager’s Customer Services department at complaints@yeeld.com.
14.2
Customer Services will try to respond to you by email as quickly as possible and at the latest within 15 Business Days.
14.3
If you’re not happy with the response from our Customer Services team, you can escalate your complaint to the TPL Issuer Complaints Department directly via email at complaints@transactpay.com. Please ensure you include the required Personal Details so we can properly identify and contact you.
14.4
If TPL’s Complaints Department is unable to respond to your complaint immediately, you will receive confirmation that your complaint has been received and a formal investigation will be conducted. You will receive a formal response of our findings within 35 Business Days of your complaint. We will make every effort to reach a resolution to your complaint and will fully explain the reasoning behind our decision.
14.5
In the unlikely event that we are unable to resolve your issue to your satisfaction, you have the right to refer your complaint to the Financial Services Commission at: Payment Services Team, Financial Services Commission, PO Box 940, Suite 3 Ground Floor, Atlantic Suites, Europort Avenue, Gibraltar or email psdcomplaints@fsc.gi.

16.1
TPL will collect certain information about the user of the Wallet and Card in order to operate the Wallet and Card. We need you to provide your Personal Data (for example, your name and address) so that we can carry out our obligations under this Agreement (for example, so that we can send you a Card with your name on it and send it to the right address). Sometimes we may need to use your Personal Data so that we can take certain steps, where you ask us to, before we enter into this Agreement. If you don’t provide the Personal Data which we ask you for, we will take steps to end this Agreement in accordance with clause 10.4(b)iii above.
16.2
We will manage and protect your personal data in accordance with all applicable data protection laws. For full and comprehensive information about when and why we collect personal information about you, how we use it and the conditions under which we may disclose it, please refer to our Privacy Policy which is provided to you at the time we collect your Personal Data.

17.1
We can update or amend this Agreement at any time if we give you at least 2 months’ notice first. If we do this, we shall ask Program Manager to notify you by e-mail from support@yeeld.com or mobile device (using the latest email address/phone number you have provided us with)].
17.2
If you do not agree with our proposed changes to the Agreement, you may end this Agreement at any time within the 2-month notice period. You can also withdraw any unused Available Balance at that time without incurring a Fee. If you don’t notify us before the 2-month deadline, we will consider that you have accepted the changes to this Agreement.
17.3
If any part of this Agreement does not comply with any regulatory requirements, then we will not rely on that part, but we’ll treat it as if it did actually reflect the relevant regulatory requirement. If we need to make operational changes before we can fully comply with a new regulatory requirement, we will make those changes as soon as we reasonably can.

21.1
Any delay or failure to exercise any right or remedy under this Agreement by us shall not be construed as a waiver of that right or remedy or preclude its exercise at any subsequent time. This means that if we don’t enforce our rights against you at a particular time, we are still able to do so at a later time.
The Wallet and Card are payment service products and not deposit or credit or banking products and, as such are not governed by the Deposit Security Scheme of Gibraltar (https://www.gdgb.gi). The deposit scheme protects customers’ money when financial firms fail. You can find out more about them at the link provided above. We will, however, safeguard your funds so that they are protected by Applicable Law if we become insolvent. If you’d like furthe
21.2
If any provision of this Agreement is deemed unenforceable or illegal, the remaining provisions will continue in full force and effect.
21.3
You may not transfer any of your rights and benefits under this Agreement. This means that the Agreement is personal to you, and you can’t transfer it to anyone else. You will remain liable until all Cards issued to you are cancelled or have expired and all sums due under this Agreement have been paid by you in full. We may transfer our rights and benefits under this Agreement to a third party and may subcontract any of our obligations under this Agreement, if we reasonably believe that this would not have a significant negative effect on your rights.
21.4
The Wallet is provided by Transact Payments Limited pursuant to its licence from the Gibraltar Financial Services Commission and the Card is issued by Transact Payments Limited pursuant to its licence from Mastercard.
21.5
Yeeld administers the Wallet and Card provided by Transact Payments Limited and is available to give You customer service support if You have any queries. Our Program Managers also conduct activities such as sponsorship, marketing, and providing the IT platform and will carry out due diligence on You.

1.1
Our agreement is with you (when you use our app/services/customer) and Yeeld Technologies Limited (Yeeld/Yeeld technologies/us/we). Yeeld's products and services are provided by Yeeld Financial Services LTD (15776510) and Yeeld Investments LTD (15775018), wholly owned subsidiaries of Yeeld Technologies LTD (14870361) registered in England and Wales with a registered office at Level 18, 40 Bank Street, Canary Wharf, London, England, E14 5NR. Whenever we refer to ‘Yeeld’, ‘we’ or ‘our’, we mean all subsidiaries and companies of Yeeld Technologies Limited.
1.2
Yeeld Investment Limited (FCA no: 1019161) is an appointed representative of WealthKernel Limited is authorised and regulated by the Financial Conduct Authority, no. 723719, registered in England and Wales, no. 09686970, with a registered office at 41 Luke St, London, UK, EC2A 4DP. Yeeld Financial Services are a co-brand of Payload Ltd, who act as a Programme Manager under Transact Payments Limited (TPL – 108217). Transact Payments Limited is a licensed electronic money institution authorised and regulated by the Gibraltar Financial Services Commission.
1.3
You agree to these terms and conditions when you register for Yeeld app. If you do not agree to these Terms and Conditions, you must not use Yeeld app. You must be 18 years old and a resident of United Kingdom to use our app and services. You can contact us through the Yeeld App. (Email, phone and postal address to be included)
1.4
You should also read Yeeld’s Privacy Policy, Cookie Policy and FAQs and Yeeld connect terms and conditions. By using the Service, you agree to the terms of our Privacy & Cookie Policy, which forms part of these Terms of Use and our agreement with you.
1.5
The Yeeld Connect Terms and Conditions shall also govern and apply in full to the use of Yeeld Companion. By accessing or using Yeeld Companion, you acknowledge and agree that you are bound by the terms set forth in the Yeeld Connect Terms and Conditions, in addition to any specific terms that may be applicable to Yeeld Companion.
How you can contact us
You can contact us through Yeeld app, you can also email us at Support@yeeld.com and call us at 02080505813.
Our Partners

2.1
We use Comply Advantage and Sumsub as trusted Know Your Customer (KYC) and Anti-Money Laundering (AML) verification providers. These partners process your personal data securely to fulfil regulatory obligations, prevent financial crime, and ensure compliance. Your personal and financial data provided during verification processes are handled according to strict privacy and data protection standards.
Privacy details of these services are available here:
- Comply Advantage Privacy Notice
- Sumsub Privacy Notice

Your Account
3.1
Your Yeeld account and associated Visa Consumer Debit Mastercard services are issued by Transact Payments Limited (“TPL”), a company authorised and regulated by the Gibraltar Financial Services Commission as an electronic money institution.
3.2
By clicking to accept the Yeeld Wallet and Visa Consumer Debit Mastercard Terms and Conditions, which govern your use of the account and card services, you agree to be bound by them. These Terms and Conditions outline your rights and responsibilities when using the account and card. You must read and accept these terms prior to using the card or wallet features in the Yeeld App. If you do not agree to them, you must not activate or use the Yeeld card services.

4.1
These terms and conditions are between you and Yeeld Investments LTD for the investment services provided in the Yeeld app. The provisions of these T&Cs will apply to you from the date on which you open your investment account via Yeeld app in accordance with the conditions set out below, and once you accept these conditions via the Application. Yeeld Connect conditions will apply for the provisions of using the app.
4.2
When you open a Yeeld Investment Account, you agree not only to our Terms and Conditions but also to the Terms and Conditions of WealthKernel, which acts as your custodian and provides trading and settlement services on your behalf. WealthKernel is authorised and regulated by the Financial Conduct Authority (FCA) under reference number 723719, which you can use to locate them on the FCA register. The company is registered in England and Wales under company number 09686970.
4.3
By opening an investment account with Yeeld, you will automatically become a customer of WealthKernel. Their Terms and Conditions apply to your account and are detailed below:
4.4
WealthKernel Limited are your custodian. This means they are responsible for holding your cash and investments safely. They are regulated by the Financial Conduct Authority (FCA). They hold your cash and investments separately from their own (ring fenced) in accordance with the FCA’s client asset rules. Their custodian terms can be found here.
CONSENT
4.5
It is important to us that you fully understand and agree to these Terms, as well as any product and service disclosures you receive. If you have any questions or require clarification, please contact us at support@yeeld.com. Unless otherwise agreed in writing, these Terms and product/service disclosures shall apply to all services we provide to you and any associated work.
If you agree to these Terms, please indicate your consent below. Your consent is required before we can provide you with our services.
By agreeing to these Terms:
- You acknowledge that you have carefully read and understood these Terms and agree that they apply to all services you receive from us.
- You elect not to receive information on every individual transaction executed on your behalf but instead receive periodic reports every three months, unless otherwise agreed.
- You authorize the transfer of information, on a confidential basis, as required under these Terms, between third parties.
- You confirm that you have read, understood, and agree to our Order Transmission Policy and Wealthkernel’s Execution Policy (https://www.wealthkernel.com/policies) concerning all transactions executed by Wealthkernel on your behalf. Furthermore, you confirm that:
  - If any of your orders may be executed outside a trading venue, we will inform you accordingly, and you expressly consent to such execution.
  - With respect to client limit orders, you expressly instruct Wealthkernel not to take measures to facilitate the earliest possible execution of unexecuted orders in a manner easily accessible to other market participants.
  - Wealthkernel may aggregate your orders with those of other clients. While Wealthkernel will act fairly, such aggregation may, in certain circumstances, be disadvantageous to you in relation to a specific order.
Representations and Warranties
You expressly understand and agree with section 10 of the Yeeld Connect terms and conditions.
Transferring funds to us
4.6
You may transfer funds from your Yeeld current account to your investment account. We only accept funds from a UK bank account that is in your name (referred to as your “Account”). Unless otherwise agreed in writing, all transfers into and out of your account will be in e-money, and payments must be made via direct debit, bank transfer, or standing order. You may also make payments through the open banking integration between our app and your banking app or website. If you choose to make a payment via open banking, the transaction will be processed by a third-party provider.
Domestic bank transfers within the UK are generally processed within three to five days, though in some cases, they may take longer. Services related to the transferred funds will only commence once the funds have been successfully received.
Funds used for investment must be wholly owned by you, with no rights held by any other individual or entity. As part of our legal and regulatory obligations concerning financial crime, we reserve the right to reject any payments if it is determined that you are not the beneficial owner of the funds.

6.1
Please refer to our fee information page for details on fees and charges yeeld.com/fees. We apply a management fee per annum published on yeeld.com/fees (inclusive of VAT where applicable) on your total assets under management invested with us. Additional taxes, costs, and charges may apply that are not levied by us. These may include, but are not limited to, fund charges, which are deducted directly by the respective fund provider.
6.2
While our fee is quoted as an annual percentage, it is deducted monthly in arrears directly from your assets under management. Fees are debited during the first week of each month. If you deposit or withdraw funds partway through a month, fees will be calculated on a pro-rata basis, meaning you will only be charged for the period your funds were invested with us during that month. A detailed breakdown of our costs and charges is available upon request. The exact amount deducted in fees can also be viewed in the Transaction History section of the app.

We will treat you as a retail client. This means that you will have the highest level of protection under the rules made by the Financial Conduct Authority (the “FCA Rules”). You will also have the right to take any complaint which you cannot settle with us to the Financial Ombudsman Service. You may at any time ask us to re-categorise you as a professional client or an eligible counterparty, but it is not our general policy to re-categorise retail clients and we can reject your request. When we refer to the FCA and the FCA Rules we also mean any regulator which may replace the FCA and the rules it may make to regulate our business.
We are covered by the Financial Services Compensation Scheme (“FSCS”) through wealth kernel. This means you may be entitled to compensation from the scheme if we cannot meet our obligations. The level of compensation depends on the type of business and the circumstances of your claim, and you are covered up to a maximum of £85,000 per person. Further details of the Financial Services Compensation Scheme are available from www.fscs.org.uk

If you have an enquiry or complaint about the Service, or simply wish to get in touch, you should contact our customer services team via our app, email complaints@yeeld.com or phone number. In the event that you have a complaint we cannot settle, you may be entitled to refer it to the Financial Ombudsman Service (FOS). Further information about the FOS is available from their website www.financial ombudsman.org.uk. Please refer to our complaints policy (www.yeeld.com/complaints) for further information on how we resolve complaints and the timeframe you can expect us to resolve your complaint. at

9.1
We may update these Terms for several reasons, including but not limited to:
- Compliance with changes in law, regulation, or rulings from the Financial Ombudsman Service.
- Adjustments in taxation affecting either our business or your account and related products.
- Requirements imposed by regulatory or tax authorities, as well as industry guidance or codes of practice.
- Evolving investment market practices, including changes in securities trading and administration that may impact your account.
- Enhancements to clarify the Terms and any other modifications that do not negatively affect you.
- Situations where fulfilling the Terms becomes impractical or impossible due to circumstances beyond our reasonable control.
- Modifications to reflect updates to our services or how they are provided.
- Revisions to applicable account charges.
- Expanding or refining the range of investments we offer.
- Enhancements to our online services driven by technological, service, or proposition improvements.
9.2
Changes that result from factors beyond our control, such as legislative amendments, or modifications that benefit you, such as service improvements, will take effect immediately. We will notify you at the next appropriate opportunity. We are not liable for any delay or failure in fulfilling our obligations if caused by events beyond our reasonable control. Such events include, but are not limited to:
- Natural disasters such as fires, earthquakes, storms, or floods.
- Explosions, nuclear incidents, or collisions.
- Acts of sabotage, riots, civil disobedience, strikes, or terrorism.
- Epidemics, national emergencies, or acts of war.
- Legal or regulatory changes imposed by governmental or regulatory bodies.
- Market conditions that affect transaction execution or settlement.
- Cyberattacks, network disruptions, or interruptions to internet or telecommunications services.
- Disruptions in essential services, including electricity and third-party service providers.
- For any material changes, we will provide written notice at least 30 calendar days before they take effect whenever possible. If advance notice is not feasible, we will notify you as soon as reasonably practicable after the change occurs.

10.1
To enable us to provide you with our services effectively, you are required to comply with certain obligations. You must agree to the terms governing our relationship and confirm that any information you provide, including within your suitability questionnaire, is accurate and not misleading. It is your responsibility to promptly notify us of any changes to the information supplied.
10.2
You must provide all necessary information and documentation required for account opening and any additional details reasonably requested to fulfill our legal, regulatory, and contractual obligations. You confirm that the investments and cash within your account portfolio are entirely owned by you and free from liens, charges, or other encumbrances. You agree not to engage in, or authorize any third party to engage in, transactions involving the investments in your account except through us. Additionally, you undertake to sign and submit any documents requested to enable us to fulfill our duties.
Specific Risks of Investments
10.3
It is essential that you understand the risks involved when making an investment. In addition to the general risks outlined in our Terms and Personal Investment Report, the following are specific risks associated with different types of assets:
10.3.1
Investments may fluctuate in value, and you may not recover the full amount invested. Financial markets and economic conditions outside our control can impact investment performance. Past performance is not necessarily indicative of future results.
10.3.2
Company equity, or shares, carries specific risks, including potential price volatility, particularly for smaller companies, whose shares may be harder to sell. Dividend payments are not guaranteed, and companies may become insolvent, rendering their shares worthless. The overall market for equities may decline, and company earnings may be volatile.
10.3.3
Overseas investments are subject to currency risk. Exchange rate fluctuations between sterling and other currencies may increase or decrease the value of your investment, independent of the performance of the asset itself.
10.3.4
It is essential that you understand the risks involved when making an investment. In addition to the gInvestments in emerging markets present additional political, regulatory, and economic risks beyond those of other international investments. These investments may be subject to sudden declines in value, difficulty in selling, or government intervention.eneral risks outlined in our Terms and Personal Investment Report, the following are specific risks associated with different types of assets:

We are committed to acting in your best interests. However, there may be situations where conflicts of interest arise, either between us and our clients or among clients. In such cases, we will notify you and obtain your consent before proceeding with any relevant transactions. We will also outline the steps taken to ensure fair treatment.
Our compliance department is responsible for maintaining control structures and procedures to comply with all applicable laws, regulations, and industry standards. We will not knowingly act in a way that disadvantages our clients and will take reasonable measures to manage any conflicts of interest fairly.

In providing our services, we may receive certain minor non-monetary benefits, provided they enhance the quality of service we deliver, are proportionate, and do not impair our ability to act in your best interests. Such benefits may include:
- General or personalized information related to financial instruments or investment services.
- Written material commissioned by issuers to promote new securities offerings, where appropriately disclosed and made widely available.
- Participation in training events, conferences, and seminars about specific financial instruments or services.
- Modest hospitality provided during business meetings or industry events.
- Research received during an evaluation trial period, provided no payments are made during or after the trial, and certain conditions are met.

We are required by anti-money laundering regulations to verify your identity, assess the nature and purpose of our business relationship, and keep the information we hold up to date. To comply with these obligations, we use electronic identity verification systems at the start and throughout our engagement with you.
Your personal information may be shared with third-party agencies that operate identity verification services. Additionally, we will verify your bank account details, which may involve sharing personal and financial information with these third parties. Their services may compare your data against bank records, electoral roll information, UK Companies House data, bankruptcy and insolvency registers, and other publicly available sources.
We are unable to provide services to you until you have successfully passed our money laundering checks.

We are committed to providing our services with reasonable skill, care, and diligence in accordance with these terms. As long as we do so, we do not accept liability for any loss, including the loss of potential gains, that may arise from the execution of our services on your behalf.
We do not provide legal, tax, or accounting advice, nor do we accept liability in relation to these matters. Your tax treatment depends on your individual circumstances and may be subject to change.
Nothing in these terms limits or excludes our liability for fraud, death, or personal injury caused by our negligence or that of our employees.

We respect your statutory rights. After opening an account and agreeing to invest with us, you have the right to cancel your investment within specified cancellation provided in WK retail terms and conditions period by providing written notice to us.
If you exercise your right to cancel within this period, we will sell your investments and return the proceeds to you. We will process the sale within a reasonable time frame, subject to market conditions and external factors beyond our control.
If the value of your investment has declined, you may not receive the full amount originally invested. Additionally, you remain responsible for any costs incurred on your behalf in relation to the sale of your investments.

Either party may terminate the provision of services at any time without penalty. If you wish to terminate, you must provide written notice, and termination will take effect upon receipt of such notice.
Upon termination, unless otherwise agreed, we will sell your investments and return the proceeds to you. This will be done within a reasonable time, subject to market conditions and external factors beyond our control.
If you terminate a Stocks and Shares ISA by selling the investments within it, the tax-free status of the ISA will be lost.
If the value of your investments has fallen, you may not recover the full amount initially invested. Additionally, payments already made to us are non-refundable.

Transferring funds to us
When you make your first investment, we will confirm our instruction to you in writing, typically via email/yeeld app chat feature.
Transfers
Unless otherwise agreed in writing, all transfers into and out of your account will be in e-money, and payments must be made by direct debit or bank transfer.
Multiple Account Holders
If an account is held jointly by more than one individual, all account holders are jointly responsible for compliance with obligations, and each is fully liable for any breaches. Notices provided to one account holder will be deemed to be provided to all, and we may act on the instructions of any one account holder.
Deceased Account Holders
In the event of the account holder’s death, we will suspend taking instructions in relation to the estate, though we may continue managing the account in accordance with prior instructions. We reserve the right to make payments to HMRC in relation to inheritance tax. Further instructions will only be accepted upon receipt of a valid grant of representation from a court.
Assignment and Transfer of Rights
You may not assign or transfer any rights or responsibilities relating to your account.
Third-Party Rights
Unless explicitly agreed otherwise, no third party has any rights under this agreement to enforce its terms.
Entire Agreement
These terms along with Yeeld Connect terms and conditions represent the complete and final agreement between the parties, superseding any prior agreements or arrangements. Neither party has entered into this agreement based on representations or statements not expressly included within it. Any remedies for misrepresentation or breach are limited to breach of contract, except in cases of fraud or fraudulent misrepresentation.
Closing Comment
These Terms apply to all investments you make with us and provide information about the manner in which we deliver our services to you. Your account with us, as well as any matters or disputes related to these Terms, shall be governed by the laws of England and Wales and shall be subject to the exclusive jurisdiction of the courts of England and Wales. These Terms and all communications between us shall be in English.
If you have any questions or if any part of these Terms is unclear, please contact us at support@yeeld.com or call 02080505813. Unless we agree otherwise in writing, these Terms shall apply to all services we provide to you and any associated work.
General provisions & applicable law
Please refer to section 17 of the Yeeld Connect terms and conditions.

Our agreement is with you (when you use our app/services/customer) and Yeeld Technologies Limited (Yeeld/Yeeld technologies/us/we). Yeeld's products and services are provided by Yeeld Financial Services LTD (15776510) and Yeeld Investments LTD (15775018), wholly owned subsidiaries of Yeeld Technologies LTD (14870361) registered in England and Wales with a registered office at Level 18, 40 Bank Street, Canary Wharf, London, England, E14 5NR. Whenever we refer to ‘Yeeld’, ‘we’ or ‘our’, we mean all subsidiaries and companies of Yeeld Technologies Limited.

2.1
If you are an individual aged 18 or over you may subscribe for an ISA with us, if you are:
- 1.
  a UK resident;
- 2.
  performing duties as a Crown employee serving overseas and paid out of thepublic revenue of the United Kingdom (typically a serving member of thearmed forces, or a diplomat), or
- 3.
  married to, or in a civil partnership with, such a person.
2.2
In addition, we will not be able to accept any payments into an existing ISA during any period that you do not meet one of the criteria in section 2.1 above.

3.1
You may subscribe to an ISA for the current tax year and each subsequent tax year by sending funds from your bank or transferring a current tax year ISA. You may do so by bank transfer, transfer of cash from an existing portfolio held with WealthKernel or by transfer from another ISA manager (subject to HMRC's ISA transfer rules).
3.2
You can only transfer to a WealthKernel ISA as a ‘Cash’ transfer. Currently, WealthKernel does not allow the option to transfer to our ISA ‘in specie’ which is where the existing assets are not sold and are reregistered to WealthKernel from the existing ISA manager.
3.3
You are permitted to subscribe to an unlimited number of ISAs within each tax year. The total of contributions to be invested in any tax year cannot be more than the maximum permitted to be invested in an ISA by the ISA Regulations for that tax year. Please note it is your responsibility to ensure that any payments into your ISA are within the annual limit.
3.4
Your ISA investment will commence on the day WealthKernel has both a valid application and receipt of your first subscription, or where you are transferring to WealthKernel from another ISA manager, on the day WealthKernel has both a valid transfer application form and receipt of the proceeds of transfer from your previous ISA manager.

4.1
WealthKernel will invest your ISA in accordance with your instructions and these terms, and subject always to the requirements of HMRC.
4.2
For each new tax year, all contributions to your Account will be allocated first to your ISA until the maximum subscription is reached for that year, or until your own pre-set limit. Once the maximum subscription or your own pre-set limit is reached, future contributions are allocated to the non-ISA remainder of your Account.
4.3
If WealthKernel decides to delegate any of our functions or responsibilities under this Schedule, WealthKernel will first satisfy itself that such person is competent to carry out any of those functions and responsibilities delegated.

5.1
You must always remain the beneficial owner of any investments held in your ISA and you must not dispose of or transfer any interest in any investment while it is held in your ISA. Additionally you must not create any charge or security on or over any investments held in your ISA; for example you must not use them as security for a loan.
5.2
Your investments will be registered in the name of WealthKernel Nominee Limited. Share certificates and other documents evidencing title to investments held in your ISA will be held by WealthKernel. Please see Schedule 1 above for the terms governing the custodian service.

8.1
You can transfer all of your ISA, together with all rights and obligations, to anotherISA manager (the “New ISA manager”). If you want to transfer your whole ISA to the New ISA manager then WealthKernel will transfer all subscriptions you have made in the current tax year and previous tax years, if applicable. We do not allow partial transfers to new ISA managers, you must transfer all the funds held within your ISA with WealthKernel.
8.2
When WealthKernel receives through your Introducer your written instructionsWealthKernel will transfer your ISA to the New ISA manager in accordance with the ISA Regulations. WealthKernel will carry out the transfer within accordance with ISARegulations, which will not exceed 30 calendar days.
8.3
You can only transfer out to another ISA manager as a ‘Cash’ transfer. This means that all assets and investments within your ISA will be sold and transferred to the new ISA manager to reinvest the funds. Currently, WealthKernel does not allow the option to transfer out to another ISA manager ‘in specie’ which is where the existing assets are not sold and are reregistered to the new ISA manager. Please note that during a cash transfer, unlike an inspecie transfer, you will be exposed to market risk on your investments while they are liquidated and sent to your new provider as cash when only then they can then be reinvested. With market movements in prices from the date the investments are sold and purchased this does mean you may get less or more investments for the cash transfer amount.

9.1
You can also instruct WealthKernel through your Introducer to transfer to you all or part of your ISA and any interest, dividends, rights or other proceeds arising from them, or sell all or some of the investments in your ISA and pay you the sale proceeds in respect of your investments (a “Withdrawal”). WealthKernel will complete the Withdrawal within a reasonable period that may take up to 30 calendar days from the date WealthKernel receives your instruction through your Introducer.
- Cash withdrawn from your ISA can be replaced within the same tax year without counting towards your annual subscription limit.
- Replacement deposits must be made with the same provider from where the cash being replaced was withdrawn.
- Please note any withdrawals not replaced in the same tax year will cause the withdrawn investments to lose their tax-efficient status.
9.2
Please note any withdrawals will cause the withdrawn investments to lose theirtax-efficient status. Amounts invested into your ISA and later withdrawn will still count towards your relevant annual ISA allowance.
9.3
In addition to the ability to withdraw from your ISA, you may also cancel your ISA if you meet the requirements set out in the “Cancellation Rights” provided for in Schedule 1. Exercising your cancellation rights within the relevant period will mean that your investments will be treated as never having entered the ISA, and so will not count towards your annual ISA allowance.

An explanation of the relationship between WealthKernel and you.
You have a relationship with WealthKernel because have an account(s) (your “Account”) with Yeeld Investments Ltd, a company incorporated in England and Wales under the company number: 15775018 and whose registers office is Level 18 Bank Street, London, England, E14 5NR (your “Introducer”). Yeeld Investments Ltd is an appointed representative, Firm Reference Number: 1019161, of WealthKernel Limited. WealthKernel Limited is authorised and regulated by the Financial Conduct Authority, Firm Reference Number: 723719.
By agreeing to these terms, you acknowledge that you have received them and read them carefully, acknowledging that they will apply to the investments you make with your Introducer through WealthKernel.
In this Schedule, unless the context otherwise requires: references to clauses are to clauses of this Schedule; the singular includes the plural and vice versa; “person” denotes any person, partnership, corporation or other association of whatever nature; and any references to any directive, statute, statutory instrument or regulations shall be references to such directive, statute, statutory instrument or regulations as from time to time amended, re-enacted or replaced and to any codification, consolidation, re-enactment or substitution thereof as from time to time in force and any reference to the Financial Conduct Authority (the “FCA”) and rules made by it shall include its successor as regulator and rules made by the successor as regulator in substitution for those rules. References to any rules by number will include references to the corresponding rules (if any) made by the successor.
In these Schedule references to any law, statute or statutory provision will include any subordinate legislation made under any of them and will be construed as references to such statute, statutory provision and/or subordinate legislation as modified, amended, extended, consolidated, re-enacted and/or replaced and in force from time to time. For the avoidance of doubt, any such references include references to the preservation, continuation of effect, conversion, or incorporation of any of them into the law of England and Wales, Scotland and Northern Ireland, whether by the European Union (Withdrawal) Act 2018 or any other legislation relating to the withdrawal of the UK from the EU.
Headings are for convenience only and have no bearing on the interpretation of these terms.

1.1
WealthKernel Limited, company number 09686970, registered office 41 Luke Street,
1.2
Agreement. You need to understand that this means you will be both a customer of your Introducer and a customer of WealthKernel.
1.3
WealthKernel is authorised and regulated by the FCA which is at 12 Endeavour Square, London E20 1JN. Its Firm Reference Number is 723719.
1.4
In consideration of WealthKernel making their services available to you, you agree that:
- 1.
  Your Introducer is authorised to enter into the WealthKernel Agreement on your behalf as your agent;
- 2.
  You are bound by the terms of the WealthKernel Agreement as summarised in this Schedule and acknowledge that the WealthKernel Agreement constitutes a contract between you and your Introducer and also between you and WealthKernel;
- 3.
  Your Introducer is authorised to give instructions to WealthKernel on your behalf and to provide information concerning you to WealthKernel and WealthKernel shall be entitled to rely on any such instructions or information without further enquiry;
- 4.
  WealthKernel is authorised to hold cash and investments on your behalf and is authorised to transfer cash or investments from your Account to meet your settlement or other obligations to WealthKernel.
1.5
WealthKernel will not provide you with investment advice nor is responsible for any investment advice given to you by your Introducer or any third party.

2.1
WealthKernel shall only accept instructions concerning your Account from your Introducer and not directly from you, unless a separate specific agreement has been made relating to instructions, (including such further mandate and/or indemnities as WealthKernel may require). Unless your Introducer notifies WealthKernel in good time in writing to the contrary to prevent the processing of any instructions, WealthKernel shall be entitled to rely upon and act in accordance with any instruction which WealthKernel believes in good faith to have been given by your Introducer on your behalf. WealthKernel reserves the right to take such action as WealthKernel considers appropriate, in accordance with the WealthKernel Agreement. WealthKernel will not be required to verify or clarify any instruction received unless WealthKernel believes this is needed for complying with its obligations. WealthKernel will not be responsible for any delays or inaccuracies in the transmission of any instructions or other information due to any cause outside WealthKernel ’s reasonable control.
2.2
WealthKernel may, in its absolute discretion, refuse to accept any order or other instruction for your Account held through your Introducer. WealthKernel will advise your Introducer of the reason for its decision unless prevented from doing so by law, Court order or instruction by the FCA.
2.3
You should direct all enquiries regarding your Account to your Introducer and not to WealthKernel.
2.4
Any communications (whether written, oral, electronic, or otherwise) between you and WealthKernel shall be in English.

3.1
Your Introducer is the agent of each Customer in its dealings with WealthKernel. Under the WealthKernel Agreement, WealthKernel has a direct contractual relationship with the Customer for the provision of (i) custody and trading services, (ii) investment management services and (iii) discretionary management services (the “Services”).
3.2
In providing the Services, WealthKernel will treat you as a retail client. This means that you will have the highest level of protection under the rules and guidance provided by the Financial Conduct Authority (“FCA”). It is open to you to request a different client categorisation to the one which WealthKernel has given you, but WealthKernel may, in its sole discretion, reject any such request. These Services depend on you retaining your Introducer. However, should your relationship with your Introducer end for reasons outside your control, WealthKernel will ensure that investments made using the Services are protected, and contact you regarding next steps. WealthKernel will use your name and contact details (in particular, your telephone number, email and/or postal address) for this purpose.
3.3
Your Introducer will share your contact details with WealthKernel in connection with the Services, as well as such personal details as may be required to allow WealthKernel to comply with relevant UK law, including the anti-money laundering and counter-terrorist financing regulations.
3.4
WealthKernel collates and processes your data to enable us to fulfil the services listed in this Agreement. For further details about processing of your personal information, please see WealthKernel Privacy Policy available at www.wealthkernel.com.
3.5
To be eligible to hold an Account and receive the Services, you must be a resident of the UK for tax purposes. WealthKernel shall treat the address which you provide your Introducer when signing up for the Services as your permanent residential address for Tax residency purposes.
3.6
Please note that neither WealthKernel nor its employees provide, nor do accept responsibility for, legal, tax or accounting advice in relation to the Services.
3.7
All communications in relation to the Services will be your Introducer’s responsibility. However, WealthKernel reserves the right to contact any Customer directly and obtain instructions or information from them if WealthKernel reasonably determines, in good faith, that such action is necessary to protect the interests of the Customers or WealthKernel.

4.1
To the extent relevant to the Services, you must comply with the following obligations:
- 1.
  confirm that you have not supplied your Introducer with information in your suitability questionnaire -if applicable- or otherwise which is inaccurate or misleading;
- 2.
  notify your Introducer promptly of any change to your information previously supplied;
- 3.
  supply your Introducer with all information, documentation or copy documentation that WealthKernel requires in order to allow WealthKernel to carry out its client onboarding procedures;
- 4.
  provide your Introducer with any additional information which WealthKernel may reasonably require in order that it can fulfil its legal, regulatory and contractual obligations;
- 5.
  confirm that the investments and cash within your Account are within your complete ownership and free from all liens, charges and any other encumbrances;
- 6.
  ensure the safe keeping of any passwords or security credentials to the Account and not deal, nor authorise anyone else to deal in the investments in your Account ;and
- 7.
  undertake to sign and/or produce, by the time your Introducer ask you to, any documents WealthKernel may need to enable it to carry out its duties on your behalf.

5.1
Contributions into your Account can be made by bank transfer, direct debit (“Direct Debit Service”), or any other method you may be advised from time to time. It is not accepted credit or prepaid cards as payment methods.
5.2
We will only accept payments into your Account in GBP, EUR or USD from a UK bank account or European bank account, or from a provider regulated and authorised under the Payment Services Regulations 2017 as amended from time to time (“Payment Services Regulations”).
5.3
WealthKernel reserves the right to reject any payments to your Account for any reason it determines including but not limited to the prevention of money laundering and counter-terrorist funding.
5.4
WealthKernel reserves the right in respect of any payment to your Account to
- 1.
  impose a minimum amount, maximum amount and frequency for direct debit payment instructions or another payment facility which can vary from time to time;
- 2.
  suspend the operation of the mandate or collection of payments;
- 3.
  withdraw the Direct Debit Service or other payment service to your Account.
5.5
When you make a payment by direct debit, your payment will be processed by an authorised third party that is subject to the Payment Services Regulations. These payments typically take 3 business days to reach WealthKernel (with a maximum of 7 business days), during which time the money is held by the relevant authorised service provider in an account protected by the relevant regulations.
5.6
If a direct debit payment is cancelled or rejected after the monies have been received, the payment will be returned, and the monies removed from your Account. This may require us to sell investments in your Account to the value of the original payment.

6.1
WealthKernel will register your investments in the name of its nominee WealthKernel Nominee Limited (“WealthKernel Nominee”). WealthKernel Nominee will hold onto your investments on your behalf, and you will be their beneficial owner.
6.2
All investments held in custody will be pooled and allocated between Customers in accordance with the FCA Rules. Accordingly, individual entitlements may not be identifiable by separate certificates, documents of title or entries on the issuers register. In the event of an irreconcilable shortfall following a default by any sub-custodian or any third party holding or delivering your investments, you may not receive your full entitlement and you may share in any shortfall on a pro rata basis with other Customers. If you need more information on this, please let WealthKernel know through your Introducer.
6.3
WealthKernel will be responsible for receiving and claiming dividends payments to be credited to your Account. WealthKernel will also credit any other payments received for your interest to your Account. All dividends or payments credited to your Account will be net of any withholding tax and other deductions required to be made by WealthKernel and/or the payee in accordance with applicable legal or regulatory requirements. WealthKernel will provide details of all such deductions required to be made by WealthKernel and will pass on such information in relation to such deductions by others as WealthKernel may receive. Your Introducer will be responsible for any costs and expenses WealthKernel may incur in receiving and claiming dividends, interest payments and any other payments. WealthKernel, WealthKernel Nominee and any relevant sub-custodian will not be responsible for reclaiming any withholding tax and other deductions. In the event US source income credited to your Account, these will carry a 30% of withholding tax (NRA withholding) and other deductions required to be made by WealthKernel and/or the payee in accordance with applicable legal or regulatory requirements.
6.4
WealthKernel shall not be responsible for informing you or your Introducer of any Corporate Actions or events concerning investments held in custody including take over offers, capital reorganisations, company meetings, conversion or subscription rights but will nevertheless do so, so far as reasonably practicable. WealthKernel shall be entitled to apply a default response, as determined in its reasonable discretion, to Corporate Actions.
6.5
WealthKernel may liquidate your investments and pay the money to charity, in accordance with the FCA Rules, if WealthKernel does not hear from you through your Introducer in relation to your investments for at least twelve years. Where WealthKernel has done so your Introducer undertakes to pay you a sum equal to the value of the asset at the time it was liquidated or paid away, should you claim an asset in the future.
6.6
WealthKernel may appoint agents, nominees, and sub-custodians (whether in the United Kingdom or overseas), to hold investments in your Account. WealthKernel may also appoint sub-custodians (including sub-custodians overseas) to hold investments for your Account on such terms as WealthKernel considers appropriate.
6.7
WealthKernel will exercise due skill, care, and diligence in the selection and monitoring of agents, nominees and sub-custodians. WealthKernel will be responsible for the acts and omissions of WealthKernel Nominee, however, in the absence of its fraud or wilful default, WealthKernel shall not be responsible for the default of any agents, nominees and sub-custodians, securities depository, intermediate broker, clearing or settlement system or participant in such a system. In the case of any investments held overseas, there may be different settlement, legal and regulatory requirements in overseas jurisdictions from those applying in the United Kingdom and there may be different practices for the separate identification of investments.
6.8
Your investments might be held by an overseas sub-custodian appointed by WealthKernel. If this is the case your investments might be registered in the name of the overseas sub-custodian. Before this occurs WealthKernel will take reasonable steps to determine that it is in your best interests for this to happen and that it is not practical for your Introducer to do otherwise, because of the nature of applicable law or market practice. When taking these steps WealthKernel will make adequate investigations of the overseas jurisdiction by reference to laws and regulations.
6.9
WealthKernel will only allow your investments to be held by an overseas sub custodian in an overseas jurisdiction that regulates and supervises the safekeeping of investments for another person who is subject to such regulation and supervision, subject to clause 6.10 below.
6.10
Your investments might be held by an overseas sub-custodian appointed by WealthKernel. If this is the case your investments might be registered in the name of the overseas sub-custodian. Before this occurs WealthKernel will take reasonable steps to determine that it is in your best interests for this to happen and that it is not practical for your Introducer to do otherwise, because of the nature of applicable law or market practice. When taking these steps WealthKernel will make adequate investigations of the overseas jurisdiction by reference to laws and regulations.

7.1
Any identifiable money (in any currency) received by WealthKernel for your Account o (“Client Money”) will be received and held by WealthKernel in accordance with the FCA Rules detailed in the Client Asset Sourcebook. Client Money will be pooled in an omnibus Client Money account with an approved banking institution (“Approved Bank”) or a qualifying money market fund selected by WealthKernel in accordance with the FCA Rules. Alternatively, WealthKernel may hold Client Money in an authorised central counterparty.
7.2
In the event of an irreconcilable shortfall in the omnibus Client Money account following a default of an Approved Bank or any third party holding Client Money (such as a clearing house, money market fund, settlement or money transfer system) you may not receive your full entitlement and may share in any shortfall on a pro rata basis with other affected Customers. We will inform you if any money in your Account is affected in this way.
7.3
Any money held in a qualifying money market fund will not be held in accordance with the FCA requirements for holding client money. In accepting these terms you provide consent to the placement of Client Money in a money market fund. These will be held in the same way as custody assets (see Clause 6 above).
7.4
WealthKernel does not pay interest on Client Money.
7.5
You agree that WealthKernel will cease to treat as Client Money any unclaimed balances and will pay these sums to charity, after a period of six years provided that WealthKernel has otherwise taken reasonable steps to trace you and return any balance to you. WealthKernel will nevertheless make good any subsequent valid claim against such balances.
7.6
In the event of WealthKernel’s insolvency your money, by virtue of having been separated from our assets and held in a Client Money account, will not be available to our creditors. However, should a third party with whom your money has been deposited default the following may happen:
- 1.
  UK bank accounts: If your money has been deposited in a UK bank account it will typically be held in a pooled account with other client’s money. If the third party bank defaults and there is a shortfall that cannot be met, then you may have to share in the loss according to the proportion of the funds attributable to you in the pooled account.
- 2.
  Non-UK bank accounts: If your money has been deposited in a non-UK bank account you face the same risk of loss as you would for a UK bank account. Additionally the laws of that country might be different from the laws and regulations in the UK. Your money might be less secure and might be treated differently than it would have been treated if it had been held in a UK bank account.
- 3.
  Money market funds: If your money is held in one or more money market funds it will typically be held in a pooled account with other clients’ money. If the fund(s) default and there is a shortfall, you may have to share in the loss on a pro rata basis. In addition, you may be subject to the laws of the country in which the money market fund is domiciled, which may be different to the laws of the UK.
- 4.
  Other third parties: If your money has been passed on to another third party there is a risk that you could suffer financial loss if that third party defaults. These third parties will not always be able to keep your money separate from their money. This means that if they become insolvent WealthKernel will only have an unsecured claim against them on your behalf. This means that they might not be able to pay WealthKernel enough money to cover all Customer’s unsecured claims.
7.7
Your Introducer will notify you as soon as possible should your Account balance fall to the point where the charges are greater than the credits.

8.1
WealthKernel will provide a service with investment options on a non-advised basis(“Execution-only service”).
8.2
In the provision of the Execution-only service, WealthKernel does not therefore check whether investments you select are suitable or appropriate for you.
8.3
Any money held in a qualifying money market fund will not be held in accordance with the FCA requirements for holding client money. In accepting these terms you provide consent to the placement of Client Money in a money market fund. These will be held in the same way as custody assets (see Clause 6 above).

9.1
WealthKernel will provide a portfolio management service (“Discretionary Management Service”) where WealthKernel will manage your investments on a discretionary basis. This means that WealthKernel will manage investments in your Account in accordance with the investment mandate selected.
9.2
You will provide your Introducer with personal information so that WealthKernel can first determine if investing using our Discretionary Management Service is suitable for you. If you are unsure or feel that your needs go beyond the scope of the Discretionary Management Service, you should obtain independent financial advice before using our Discretionary Management Service.
9.3
Any money held in a qualifying money market fund will not be held in accordance with the FCA requirements for holding client money. In accepting these terms you provide consent to the placement of Client Money in a money market fund. These will be held in the same way as custody assets (see Clause 6 above).
9.4
In the event of WealthKernel’s insolvency your money, by virtue of having been separated from our assets and held in a Client Money account, will not be available to our creditors. However, should a third party with whom your money has been deposited default the following may happen:
- 1.
  UK bank accounts: If your money has been deposited in a UK bank account it will typically be held in a pooled account with other client’s money. If the third party bank defaults and there is a shortfall that cannot be met, then you may have to share in the loss according to the proportion of the funds attributable to you in the pooled account.
- 2.
  Non-UK bank accounts: If your money has been deposited in a non-UK bank account you face the same risk of loss as you would for a UK bank account. Additionally the laws of that country might be different from the laws and regulations in the UK. Your money might be less secure and might be treated differently than it would have been treated if it had been held in a UK bank account.
- 3.
  Money market funds: If your money is held in one or more money market funds it will typically be held in a pooled account with other clients’ money. If the fund(s) default and there is a shortfall, you may have to share in the loss on a pro rata basis. In addition, you may be subject to the laws of the country in which the money market fund is domiciled, which may be different to the laws of the UK.
- 4.
  Other third parties: If your money has been passed on to another third party there is a risk that you could suffer financial loss if that third party defaults. These third parties will not always be able to keep your money separate from their money. This means that if they become insolvent WealthKernel will only have an unsecured claim against them on your behalf. This means that they might not be able to pay WealthKernel enough money to cover all Customer’s unsecured claims.
9.5
WealthKernel will provide you through your Introducer with the required information to allow you keep track of the Discretionary Management Service performance.

10.1
When providing the Services, WealthKernel will use its best efforts, in accordance with its Order Execution Policy. For an explanation of how transactions are executed on your behalf, please see WealthKernel’s Order Execution Policy available at www.wealthkernel.com.
10.2
This sets out how WealthKernel ensures that, when executing transactions on your behalf, all sufficient steps are taken to obtain the best possible result for you on a consistent basis, taking into account relevant factors, including: price, cost, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of your order.
10.3
This sets out how WealthKernel ensures that, when executing transactions on your behalf, all sufficient steps are taken to obtain the best possible result for you on a consistent basis, taking into account relevant factors, including: price, cost, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of your order.
10.4
Furthermore, you confirm that:
- 1.
  your orders may be executed by a third-party broker other than WealthKernel;
- 2.
  your orders may be executed outside of a regulated market, multilateral trading facility or organised trading facility, and by accepting this agreement, you expressly consent to the execution of your orders in such circumstances;;
- 3.
  WealthKernel has your express instruction not to take measures to facilitate the earliest possible execution of any unexecuted orders in a manner that is easily accessible to other market participants; and
- 4.
  WealthKernel may aggregate your order with those of other clients. Whilst WealthKernel will act fairly, the effect of this aggregation may work to your disadvantage in relation to a particular order.

13.1
Below are set out the general risks involved when investing:
- 1.
  Insolvency risk: is the risk of losing (part of) the investment when the issuer of the asset defaults.
- 2.
  Price risk: is the risk of a decline of an investment, mainly influenced by the performance of the issuer of the asset.
- 3.
  Market fluctuation and volatility: is the risk of losing (part of) the investment due to market circumstances and factors that affect the overall performance of the financial markets.
- 4.
  Geographic risk: is the risk of losing (part of) the investment due to the political and economic instability of the country in which the company you invested in is established and/or active or where a bond has been issued.
- 5.
  Inflation and interest rate risk: is the risk that inflation and interest rates undermine the investment returns and cause a decline in purchasing power.
- 6.
  Liquidity risk: is the risk of limited ability to buy or sell an investment that could lead you to run the risk of being unable to sell your investment or being unable to do so for a reasonable price.
- 7.
  Currency risk: this risk occurs when you invest in other currencies than GBP, as if the exchange rate of the other currency compared to GBP changes, this will impact the value of your investment.
- 8.
  Timing risk: this risk occurs when your order is aggregated with other orders and executed during an execution window, as due to the inherent nature of a moving market, it is likely that the execution price will differ from the price at the moment of instructing the order.
- 9.
  Legal risk: is the risk of legal actions or changes, including those taken by governments or regulators, that undermines the value of an investment, and the ability to sell it.
- 10.
  Service interruption risk: is the risk of not being able to submit orders or your order being cancelled due to an interruption of the Services caused by a market issue, and external provider or our own systems.
13.2
In addition to the above, below are set out the specific risks of investing in fractional shares:
- 1.
  Rounding: WealthKernel rounds all fractional holdings to four decimal places. Rounding may also affect your ability to be credited for cash dividends, stock dividends and stock splits. For example, WealthKernel does not credit cash dividends under 0.01 GBP. WealthKernel reserves the right to modify in the future the number of decimal places so that the minimum fractional holding for any investment may increase.
- 2.
  Transfer of fractional shares: fractional shares are not transferable. If you close your Account, the fractional shares held in your Account will need to be liquidated.
13.3
In addition to the above, collective investments such as Exchange Traded Funds (ETFs) carry their own specific risks that need to be reviewed by you in their Key Information Document.
13.4
You should also consider that your liability to tax depends on your personal circumstances, and independent advice should be sought if required.
13.5
If any of the risks outlined above are unclear or you would like to discuss the risks you face in further detail, please contact your Introducer.

14.1
As As continuing security for the performance of your obligations pursuant to the terms of the WealthKernel Agreement including, without limit, the payment of all sums due to WealthKernel by you, or through your Account, you agree to grant WealthKernel to the extent permitted under applicable law or regulation a pledge, lien and right of set-off over and in respect of, all and any investments, documents of title to property, documents representing property and all money, investments and other assets of any nature held by or subject to the control of WealthKernel (its nominees and sub-custodians) for your account (including, without limitation, the benefit of all contractual rights and obligations and any proceeds of sale), to recover its costs, charges and any other sums incurred in relation to the provision of the Services, including as appropriate to realise sell, charge, pledge, deposit, borrow against or otherwise deal the cash or assets within your Account to meet those costs charges and other sums.
14.2
WealthKernel shall have, to the greatest extent permitted by law and the FCA Rules, all of the rights of a secured party with respect to any money or other assets charged to it and you confirm that you will, at the request of WealthKernel, take such action as may be required to perfect or enforce any security interest and each irrevocably appoints WealthKernel as their attorney to take any such action on their behalf.
14.3
You represent and warrant to WealthKernel that you are the sole and beneficial owner of all money, investments or other assets of any nature transferred to or held by WealthKernel their nominees and sub-custodians or the same are transferred to or held by WealthKernel their nominees and sub-custodians with the legal and beneficial owner's unconditional consent and, in any event, are and will be transferred to or held by WealthKernel their nominees and sub-custodians free and clear of any lien, charge or other encumbrance and that you will not charge, assign or otherwise dispose of or create any interest therein.
14.4
Provided WealthKernel has not been negligent, fraudulent or wilful default, WealthKernel shall have no liability to you for any cost, loss, liability and expense, including without limit any loss of profit or loss of opportunity incurred or suffered by you in consequence of any exercise by WealthKernel of any right or remedy under this clause and any purchase, sale, or other transaction or action that may be undertaken by WealthKernel shall be at such price and on such terms as WealthKernel shall, in its absolute discretion, determine.
14.5
In exercising any right or remedy pursuant to this clause, WealthKernel is authorised to combine accounts, effect such currency conversions and enter into such foreign exchange transactions with, or on behalf of, you, at such rates and in such manner as WealthKernel may, in its absolute discretion, determine.

15.1
Nothing in the terms set out in this Agreement excludes or restricts any liability of WealthKernel resulting from:
- 1.
  death or personal injury; or
- 2.
  fraud or wilful default of WealthKernel.
15.2
Subject to clause 15.1, WealthKernel shall not in any event be liable for loss of profits, loss of opportunity, loss of business, loss of savings, loss of goodwill, claims by third parties, loss of anticipated savings (whether direct or indirect) or for any type of special, direct, indirect or consequential loss (or the loss of an opportunity to gain) howsoever caused, even if caused by WealthKernel negligence and/or breach of contract and even if such loss was reasonably foreseeable or WealthKernel had been advised of the possibility of the Customer incurring the same.
15.3
In particular, WealthKernel is not liable for
- 1.
  death or personal injury; or
- 2.
  fraud or wilful default of WealthKernel.

16.1
WealthKernel will always endeavour to act in your best interests as our client. However, circumstances can arise where WealthKernel or one of its other clients may have some form of interest in business being transacted for you.
16.2
WealthKernel or its associates may provide services or enter into bargains in relation to which WealthKernel, or its associates, has, directly or indirectly, a material interest or a relationship of any description with a third party which may involve a conflict of interest or potential conflict of interest with you. WealthKernel or any of its associates may, for example:
- 1.
  for its interests be the counterparty to a transaction that is executed by WealthKernel (whether or not involving a mark-up or a mark-down by WealthKernel or its associates);
- 2.
  for its interests have a (long or a short) position in the investments to which any of your instructions relate; or
- 3.
  for its interests be connected to the issuer of the investment to which any instructions relate.
16.3
WealthKernel may receive remuneration from fund managers or Approved Banks in connection with WealthKernel providing services to them. These payments are calculated by reference to the agreement WealthKernel has with that person. If that means there will be a deduction in the value of your Account, that deduction will be disclosed to you as set out in the FCA Rules.
16.4
WealthKernel may as part of the provision of the Services receive acceptable minor-monetary benefits.
16.5
WealthKernel has adopted conflict of interest policies in accordance with the FCA’s requirement for authorised firms to pay due regard to the interests of their Customers, treat them fairly and manage conflicts of interest fairly, both between themselves and their Customers and between different Customers.
16.6
You acknowledge that neither WealthKernel nor any of its associates is required to disclose or account to you for any profit made as a result of acting in any manner described above, except as set out in the FCA’s then current rules.

17.1
In the event of any complaint regarding WealthKernel ’s services you should contact in writing by email to complaints@wealthkernel.com.
17.2
WealthKernel will, as soon as is practicable, investigate the matter with any employees who may be directly concerned to determine the appropriate course of action. After investigating WealthKernel will write to you detailing the results of the investigation and offering, where appropriate, redress.
17.3
If WealthKernel does not deal with your complaint to your satisfaction, you can refer it to the Financial Ombudsman Service. This does not prevent you from taking legal proceedings. The Financial Ombudsman Service’s contact details are:
Financial Ombudsman Service
Exchange Tower
London E14 9SR
Tel: 0800 023 4567
Email: complaint.info@financial-ombudsman.org.uk
www.financial-ombudsman.org.uk
17.4
WealthKernel will consider a complaint to be closed in any of the following circumstances:
- (a)
  If at any time a complainant has accepted in writing an offer of redress or has written to WealthKernel confirming that he/she is satisfied with WealthKernel ’s response to the complaint (or simply confirms in writing that he/she wishes to withdraw the complaint). The Head of Compliance will write to the complainant acknowledging receipt, making redress (if appropriate) and confirming that the complaint has been closed; or
- (b)
  If you have not replied to an initial or interim letter offering redress having been invited to do so within eight weeks of the date of the letter and such offer of redress has been made, or set aside for you to claim if it cannot be made because you have not replied.

18.1
WealthKernel does not charge you directly for their Services, rather WealthKernel provides the Services on the basis that your Introducer pays their fees on your behalf from your Account.
18.2
In the event of non-payment or late payment of fees, you agree that WealthKernel may use, sell, retain or set-off assets held on your behalf. WealthKernel will only exercise this right if WealthKernel has asked your Introducer for payment in writing and the sum is outstanding for 30 calendar days from the date of our request.

20.1
WealthKernel will always honour your statutory rights. After agreeing to invest with your Introducer, you are still entitled to cancel your investment for up to 14 calendar days after having opened your Account (the “Cancellation Period”). This is done by sending a written notice of the cancellation to the Introducer.
20.2
If you cancel your investment within the Cancellation Period, WealthKernel will sell your investments and return the money from any sale to you. WealthKernel will sell your investments within 2 business days (on which the relevant markets are open) of receiving the cancellation instruction, subject to circumstances beyond our control.
20.3
Please be aware that if the value of your investment(s) has fallen you will not get back the full amount you invested. You will also be liable for any costs to be charged by your Introducer in order to sell the investments.

21.1
WealthKernel may amend these terms at any time. If you object to any of these amendments to these terms, such amendments will not be binding on you, but your Account will be suspended with immediate effect and move to close your Account as soon as reasonably practicable. Any amended version of this terms will supersede any previous version of the agreement entered into WealthKernel and you.
21.2
Changes to the terms of this Schedule may take place for the following reasons:
- 1.
  Changes to relevant law or regulation, or a decision of the Financial Ombudsman Service.
- 2.
  Changes to the way WealthKernel are taxed (including the requirement to pay any government or regulatory levy), or you and your product are taxed.
- 3.
  Changes required by any regulatory or tax authority or industry guidance or codes of practice.
- 4.
  Changes in the way investment markets work, including changes in investment/securities dealing or administration which may affect your Account.
- 5.
  To make the terms easier to understand and any other changes that are not detrimental to you.
- 6.
  If it becomes impossible or impractical, in WealthKernel’s reasonable opinion, to carry out any of the terms as a result of circumstances beyond WealthKernel’s reasonable control.
- 7.
  To reflect changes to the Services or the manner in which WealthKernel provides them to you.
- 8.
  To reflect changes to the level of charges applicable to your Account.
- 9.
  To reflect changes to the range of investments available to you from time to time.
- 10.
  To reflect improvements to the Services.
21.3
Changes to the terms of this Schedule which are due to reasons outside WealthKernel’s control (e.g. for the purposes of complying with regulatory requirements) or are not detrimental to you (e.g. improvements to the Services) will take effect immediately and WealthKernel will notify you at the next appropriate opportunity. WealthKernel will not be liable to you for any failure or delay in performing its obligations under this Schedule if such failure or delay is due to any cause outside its reasonable control. Events outside our reasonable control include, but are not limited to:
- 1.
  Acts of God, fire, earthquake, storm or flood.
- 2.
  Explosion, nuclear accident or collision.
- 3.
  Sabotage, riot, civil disobedience, strikes, terrorism.
- 4.
  Epidemic, national emergency (whether in law or fact), or act of war.
- 5.
  Any change to the law or regulation of a governmental or regulatory body.
- 6.
  Market conditions affecting the execution or settlement of transactions in respect of your Account.
- 7.
  Any targeted network attack or interruption of the internet or other telecommunications service.
- 8.
  Loss of supply of essential services including electrical power and third party services. Any other cause beyond our reasonable control which prevents WealthKernel administering your Account for a given period of time.
21.4
Otherwise, your Introducer will notify you about any material changes at least 30 calendar days before a change becomes effective and where this is reasonably possible. You will be deemed to accept and agree to any and all amendments notified to you unless you notify your Introducer otherwise within such period.
21.5
If it is not, your Introducer will write to you at the earliest opportunity after the change has taken place.

22.1
Your relationship with WealthKernel will terminate if you close your Account.
22.2
If for whatever reason your Introducer’s relationship with WealthKernel ends, your Introducer will tell you about any arrangements with another service provider and will tell you what that means to you and your Account will be closed.
22.3
If you do not accept the option to transfer to another service provider and your funds cannot be returned to you for any reason, WealthKernel will charge you £2 per account, per month, adjusted by Consumer Price Index ( hereinafter, “CPI”) annually.
22.4
Additionally, WealthKernel may terminate or suspend the Services in exceptional circumstances. Exceptional circumstances include the following:
- 1.
  if WealthKernel has good reason to suspect that you are behaving fraudulently or otherwise criminally;
- 2.
  if you have not given your Introducer any information WealthKernel needs, or WealthKernel has good reason to believe that information you have provided is incorrect or not true;
- 3.
  if you have not given your Introducer any information WealthKernel needs, or WealthKernel has good reason to believe that information you have provided is incorrect or not true;
- 4.
  if WealthKernel has good reason to believe that continuing to provide the Services to you could damage WealthKernel’s reputation or goodwill;
- 5.
  if you've been declared bankrupt; or
- 6.
  if WealthKernel has to do so under any law, regulation, court order or supervisory authority instruction.
22.5
WealthKernel may also decide to terminate or suspend your Account for other reasons. WealthKernel would contact you through your Introducer at least 30 business days before WealthKernel does this.

23.1
WealthKernel is required to and will observe and apply the requirements of the law of England applicable to the provision of the Services under the WealthKernel Agreement. Notwithstanding the foregoing, WealthKernel’s obligations to you shall be limited to those set out in this Schedule and WealthKernel shall not owe any wider duties of a fiduciary or any other nature to you.
23.2
Requests for paper statements of transactions carried out or a valuation of your account(s) will be billed at £15 per statement, per account adjusted for CPI annually.
23.3
If you die, WealthKernel will suspend taking instructions in relation to your estate. This means that WealthKernel will continue to manage your Account in accordance with any instructions you have given WealthKernel so far. WealthKernel also reserves the right to exercise our absolute discretion to make payments to HMRC to help you deal with inheritance tax. Otherwise, WealthKernel will only take further instructions once WealthKernel has been presented with a valid grant of representation from a court.
23.4
No person other than you and your legal representatives shall be entitled to enforce these terms set out in this Schedule in any circumstances. You may not assign or transfer any of your rights or responsibilities in relation to your Account with WealthKernel.
23.5
Any failure by WealthKernel (whether continued or not) to insist upon strict compliance with any of the terms set out this Schedule shall not constitute nor be deemed to constitute a waiver by WealthKernel of any of its rights or remedies.
23.6
These terms set out in this Schedule shall be governed by English law and you hereby irrevocably submit for the benefit of WealthKernel to the non-exclusive jurisdiction of the courts of England and Wales.

1.1
“We”, “us” or “our” in these Terms refer to WealthKernel Limited and its employees. “Client”, “you” and “your” refer to you as a member, or somebody intending to become a member, of the Scheme.
1.2
These are the standard Terms that apply to your membership of the Scheme and your SIPP. It is important that you read these Terms carefully because they apply to all our dealings with you in relation to your SIPP.
1.3
These Terms apply in addition to the standard Retail Client Terms in Schedule 1, which are the standard terms and conditions for investing with us (Schedule 1). To the extent that there is any conflict between these Terms and Schedule 1, these Terms will take priority in relation to your SIPP.
1.4
Headings are for convenience only and have no bearing on the interpretation of these Terms.
1.5
Words in capitals are defined terms with the meanings set out in Section 31.

2.1
These Terms form a legally binding agreement between you, as the member of your SIPP, and us as the operator of your SIPP and govern the provision of your SIPP. Please read all the Terms carefully as they are an important part of your agreement with us.
2.2
These Terms form part of a set of documents in relation to your SIPP, all of which should be read together:
- 2.2.1
  Key Features;
- 2.2.2
  Schedule of Fees;
- 2.2.3
  Schedule of Allowable Investments;
- 2.2.4
  Trust Deed and Rules; and
- 2.2.5
  the Application Form completed online.
2.3
These documents are available on our website (http://yeeld.com/) or the mobile app and a copy of the Trust Deed and Rules is available from us on request. Please let us know if you would like hard copies of any of these documents.
2.4
By applying to become a member of the SIPP, you accept these Terms when you sign our member declaration section of the Application Form. These Terms apply from the date that we receive and accept a properly completed Application Form to become a member of your SIPP.

3.1
WealthKernel is the Operator of the Scheme and the Scheme Administrator.
3.2
WealthKernel is authorised and regulated by the Financial Conduct Authority (FCA) for the provision of the Scheme and your SIPP and is entered on the Financial Services Register under firm reference number 723719. We are authorised for the purposes of establishing, operating and winding up a personal pension scheme. Your SIPP is a product regulated by the FCA.
3.3
The Trustee is the trustee of the Scheme and your SIPP. The Trustee is a non-trading company and is a bare trustee, meaning that its sole role is to act as the trustee of the Scheme and hold the legal title to assets of the Scheme and your SIPP. The Trustee acts only on and in accordance with directions given by us.
3.4
The assets within your SIPP are held on trust by the Trustee in accordance with the Trust Deed and Rules and are kept separate from assets of WealthKernel.
3.5
In accordance with the FCA Rules we will classify you as a ‘retail client’. This means you are entitled to the greatest level of protection under the UK regulatory regime. You can ask not to be treated as a retail client, however we retain the right not to accept this request. If you request to be treated as a type of client other than a retail client you will lose various protections afforded to you, including the ability to complain to the Financial Ombudsman Service (FOS) and potentially the right to make a claim under the Financial Services Compensation Scheme (FSCS).
3.6
Your SIPP has been established under the Scheme. The Scheme is governed by the Trust Deed and Rules, as amended from time to time, and is a Registered Pension Scheme. The purpose of the Scheme is to provide pension and lump sum benefits to its members and their beneficiaries.
3.7
We reserve the right to vary from time to time the structure of the Scheme and the way your SIPP is held under the Scheme. Any such amendment, variation or modification of the structure of the Scheme will not amount to an amendment of these Terms.
3.8
If there are any inconsistencies between these Terms and the Trust Deed and Rules, the Trust Deed and Rules shall prevail.

4.1
Your Membership is based on the declarations you make to us and the information that you disclose to us on the Application Form. By submitting your Application Form to us you agree to establish your SIPP and to become a Member of the Scheme. We reserve the right to reject applications at our discretion.
4.2
You may not be a Member of the Scheme if you are under the age of 18.
4.3
Your SIPP has been established for the sole purpose of the provision of pension and lump sum benefits for you and eligible individuals. Benefits are payable from your SIPP in accordance with the Trust Deed and Rules and are subject to legal and regulatory requirements, including under the Act.

5.1
We will provide the following Services:
- 5.1.1
  Establishing your SIPP under the Scheme and providing documentation and or information to you that is required for you to claim tax relief in relation to your SIPP;
- 5.1.2
  Operating your SIPP in accordance with legal and regulatory requirements;
- 5.1.3
  Administering your SIPP, including (but not limited to):
- (a)
  setting up and operating a Cash Asset Line;
- (b)
  maintaining necessary records, including a record of contributions paid to your SIPP;
- (c)
  liaising with you and/or your financial adviser or your other duly authorised representative in respect of changes to the Scheme;
- (d)
  acting on and implementing your investment instructions, except where to do so would be prohibited by regulations, law, or by our investment policy (see Section 10);
- (e)
  making any required arrangements for the purchase or sale of investments held under your SIPP;
- (f)
  acting in line with your instructions, receiving income on investments held under your SIPP and paying costs, charges and expenses due in relation to your SIPP;
- (g)
  payment of the benefits due under your SIPP, including in cash and/or, in certain circumstances, by an in-specie payment and/or by the purchase of an annuity; and
- (h)
  paying charges from your SIPP due to any financial adviser or other duly authorised representative who you have appointed, as agreed in writing between you and your financial adviser or your other duly authorised representative.
5.2
We will provide such other Services in relation to your SIPP as we may agree with you in writing from time to time (on such terms, including the payment of any additional fees, that we agree with you) or that we are required to provide by law or regulatory requirements.
5.3
We are not financial advisers and we will not provide nor be under any duty to provide any financial advice as to whether a SIPP is the right product for you, nor will we recommend or advise in connection with your SIPP or the suitability or appropriateness of any actual or proposed investments held under your SIPP or the investment strategy.
5.4
You should seek advice from a suitably qualified and regulated firm or individual before establishing your SIPP. We recommend you appoint advisers, including a financial adviser and/or investment manager, to advise in connection with your SIPP. You may also require tax, legal or other types of specialist advice. The costs of the advice may normally be met from your Member Fund, however you must not enter into any agreements with advisers or other duly authorised representative where the fees and charges cannot be met by you.
5.5
For the avoidance of doubt, we will not provide (and shall not be deemed to have given) any financial, investment, legal, tax or other advice in relation to your SIPP or any investments held under your SIPP. Contents on our website, mobile app, any other linked websites or material must not be construed as financial, investment, legal, tax or other advice of any kind.

6.1
You may personally contribute to your SIPP (subject to them satisfying such client identification checks as we may require from time to time) with single one off or regular payments from your personal bank account. We are currently unable to accept employer contributions. If we notify you in the future that this has changed, the following provisions of this clause 6 will also apply, in particular clause 6.8.
6.2
By becoming a member of your SIPP and signing the Application Form, you are undertaking to agree that the contributions you pay in any tax year shall not exceed the maximum permitted by the Act and are within allowable limits for tax relief, including the Annual Allowance and the MPAA. We may repay any overpaid tax relief and interest on the overpayment on demand by HMRC from your SIPP without your further authority.
6.3
We will assume all contributions paid by you are eligible for tax relief and it is your responsibility to let us know if this is incorrect. At our discretion, we may accept contributions that do not qualify for tax relief.
6.4
For personal contributions which qualify for tax relief (excluding any employer contributions), we will claim basic rate tax relief from HMRC on your behalf monthly, in arrears. It can take between six and eight weeks from the end of the month in which you make the contribution to receive tax relief on your personal contributions from HMRC. Tax relief is not available for investment until it is received by us from HMRC and credited to your SIPP.
6.5
You will be responsible for claiming any higher or additional rate tax relief from HMRC via your self-assessment tax return. These monies will not be credited to your SIPP.
6.6
Where contributions are paid by your employer, the employer will make a gross contribution to your SIPP. Your employer will reclaim tax relief directly from HMRC against its own liability to tax. You are not personally entitled to receive tax relief on these contributions. Your employer will be required to provide us with confirmation of any contributions paid on your behalf.
6.7
You are responsible for ensuring that all contributions are within allowable limits set by HMRC and for the reporting and payment of any tax charges that may be applied if you exceed such limits. You will not receive tax relief on contributions that exceed your UK relevant earnings or which exceed the Annual Allowance. Any amount paid into a Registered Pension Scheme above the Annual Allowance will be subject to a tax charge at your marginal rate. If you have taken benefits under your SIPP or transferred out of your SIPP, you agree to indemnify us and keep us indemnified in relation to any tax due to HMRC as a result of any excess contribution being paid.
6.8
You will be required to provide to us appropriate documentation (as we may request) to support any contributions made to your SIPP. We reserve the right to reasonably refuse a proposed contribution unless you provide appropriate documentation to support its eligibility.
6.9
Once a contribution has been accepted, it cannot normally be refunded. HMRC pension rules only permit refunds in very limited circumstances.
6.10
You should consult a professional adviser if you have any questions regarding contributions to your SIPP. We cannot advise you as to the appropriateness (including any tax consequences) of any contributions made to your SIPP and we shall have no liability in respect of this.
6.11
If at the time you make a contribution you have applied to HMRC for protection against the Standard Lifetime Allowance, you should take advice before making contributions to your SIPP as this could invalidate your protection and may result in a Lifetime Allowance Charge being levied by HMRC. We will not be liable for any loss in the event of a Lifetime Allowance Charge, nor will we be liable for any other tax charge or loss in respect of contributions to your SIPP.
6.12
Contributions paid to your SIPP, the benefits that you may draw from your SIPP and the investment strategy that you may choose to follow are all subject to the Trust Deed and Rules, the tax regime under the Act and requirements of HMRC and may change in the future.

We do not currently allow benefit payments from your SIPP. If we notify you in the futurethat this has changed, the following provisions of this clause 7 will apply.
7.1
The benefits payable from your SIPP are not guaranteed. The amount available to provide benefits at any date will be the amount of your Member Fund, which will depend on a number of factors including (but not limited to):
- 7.1.1
  the contributions made to your SIPP;
- 7.1.2
  the market value of the investments and assets held within your Member Fund;
- 7.1.3
  the returns from the investments;
- 7.1.4
  the charges, fees, expenses and any taxes deducted; and
- 7.1.5
  any cost of converting your SIPP investments into an income when you decide to take benefits.
7.2
We will pay benefits out of your SIPP in accordance with the Trust Deed and Rules and applicable HMRC rules and requirements under the Act at the time.
7.3
Benefits will only be paid in Sterling to a UK bank account in your name or to an account on which you are a joint signatory.
7.4
At Pension Date you may, subject to the conditions set out in the rest of these Terms and the Trust Deed and Rules, choose from one or more of the following benefits:
- 7.4.1
  a pension commencement lump sum;
- 7.4.2
  an annuity;
- 7.4.3
  pension drawdown;
- 7.4.4
  Uncrystallised Withdrawals; or
- 7.4.5
  any other benefits permitted under the Trust Deed and Rules and under the Act.
7.5
You will normally be eligible to take a portion of your Member Fund as a tax-free lump sum at your Pension Date. Currently this is 25% of the total value of your Member Fund. A different amount may be available if you have Transitional Rights.
7.6
You can take income in the form of pension drawdown from a drawdown fund created at a Pension Date provided you meet the minimum requirements set out in the Act and regulations under the Act in force. Where you are taking pension drawdown you may also be able to receive a pension commencement lump sum payable from the newly created drawdown fund, with the balance used to provide you with an income.
7.7
You can use all or part of your Member Fund to set-up flexi-access drawdown. You can take up to 25% of the value tax free and any further withdrawals taken will be taxed at your marginal tax rate in accordance with the tax code we receive from HMRC for you. Subject to HMRC rules, there is no upper or lower limit to how much income you can take from the flexi-access drawdown fund.
7.8
Uncrystallised Withdrawal is the option to take ad-hoc withdrawals from your Member Fund without the need to set up a drawdown fund. Subject to HMRC rules, 25% of the total withdrawal amount will be tax free and the rest taxable at your marginal income tax rate.
7.9
You can use some or all of your Member Fund to buy an annuity at Pension Date \ from an annuity provider before or after taking pension drawdown. We will deduct from the annuity purchase price any outstanding charges.
7.10
When you reach age 75, we, as Scheme Administrator, are required to conduct a Lifetime Allowance test on your Member Fund. In the event of a Lifetime Allowance Charge being payable, we will deduct this amount from your Member Fund and remit it to HMRC.
7.11
You may have the option of taking the proceeds of your Member Fund as a Serious Ill-Health Lump Sum. The Serious Ill-Health Lump Sum must satisfy the conditions set out in the Trust Deed and Rules and under the Act.

8.1
On your death, benefits will be paid from your SIPP to beneficiaries in accordance with the Trust Deed and Rules and requirements under the Act applicable at the time. We may at our discretion decide who receives the death benefits, taking into account, but not being bound by, any Expression of Wishes.
Death before age 75
8.2
If you die before the age of 75, the following benefits may be payable:
- 8.2.1
  lump sum death benefit;
- 8.2.2
  pension; or
- 8.2.3
  a combination of the above.
8.3
Subject to applicable law and regulations, we may pay out the total value of your Member Fund and, if applicable, drawdown fund as a lump sum under the Discretionary Trust, unless a person to whom this benefit is to be paid under the Discretionary Trust elects to receive part or all of it as a pension instead.
8.4
The person to whom we may pay the lump sum death benefit under the Discretionary Trust may use all or part of the Member Fund and, if applicable, drawdown fund to provide a pension by asking us to purchase an annuity from an annuity provider or to make a transfer payment to another Registered Pension Scheme or QROPS to take pension drawdown.
Death after age 75
8.5
The same lump sum and pension benefits are available to your beneficiaries, subject to any lump sum death benefits being taxed and any benefits paid out through a beneficiary drawdown fund and taxed at the beneficiaries’ highest rate of marginal tax.
8.6
The person to whom we may pay the lump sum death benefit under the Discretionary Trust may use all or part of your drawdown fund to provide a pension by asking us to purchase an annuity from an annuity provider or to pay income to them in the form of flexi-access drawdown (and the relevant provisions of Section 7 will apply as appropriate).
8.7
In the event of your death, any investments will continue to be held until payments have been made under the Discretionary Trust. During this time, the value of investments may fluctuate and we will not be liable for any loss in the value of your Member Fund due to a fall in the value of the investments between the date of your death and the date of the final payment.

9.1
At your request, we may at our discretion accept a transfer of all or part of your benefits under another Registered Pension Scheme or a recognised overseas pension scheme (ROPS) into your SIPP. Before making a transfer, you may be required to obtain advice from a financial adviser and you will be required to obtain regulated financial advice from a qualified pension transfer specialist for transfers from a scheme with safeguarded benefits, for example final salary schemes (also known as defined benefit occupational pension schemes). We reserve the right to refuse a transfer of all or part of your pension saving under a Registered Pension Scheme or ROPS where the transfer is from a scheme with safeguarded benefits. Neither we nor the Trustee gives or is authorised to give advice, nor do we or the Trustee check your transfer application for suitability.
9.2
You are responsible for initiating all transfer instructions. We do not accept any responsibility for delays in receiving a transfer. All transfer payments will be held initially in the Cash Asset Line and will then be paid or invested in accordance with your instructions.
9.3
In-specie transfers from a money purchase pension scheme or a personal pension scheme may be made subject to our approval. You may need to provide further information to assist with the transfer.
9.4
Subject to our legal obligations, we reserve the right at our discretion to refuse to accept any transfer into your SIPP or to make any transfer out of your SIPP.
9.5
You can transfer all or part of your SIPP to another Registered Pension Scheme or a QROPS if the transfer satisfies HMRC requirements and where we are satisfied that appropriate and sufficient due diligence has been carried out.
9.6
If you are only transferring part of your SIPP, you must instruct us which assets to sell before the transfer (unless the transfer is to be made in cash or in specie only). There may be a cost for selling these assets. If it is necessary to sell a property or any other asset, the transfer will be delayed until the property or asset has been sold. If you want to transfer part of your SIPP from which you are taking drawdown pension, that part must be transferred in full to another pension scheme that can provide you with drawdown pension.
9.7
We may receive small additional payments after you have transferred out all your benefits under your SIPP, for example from a subsequent share dividend payment, or an interest payment. Where possible, we will pay these to the receiving provider or beneficiary after first deducting our fee. If the receiving provider refuses to accept the funds, we will deduct our fee for dealing with this and pay any residue to you, where permitted under HMRC rules, or to another Registered Pension Scheme or QROPS of your choice.

10.1
You, as the Member of your SIPP, are responsible for selecting the assets and investments of your Member Fund, in conjunction with your financial adviser or your other duly authorised representative if you have appointed one. You take full responsibility for the suitability and appropriateness of the investments that you make through your SIPP and, if applicable, the management of those investments. Neither the Trustee nor we accept any liability for any decisions relating to the purchase, retention and sale of the investments within your Member Fund.
10.2
We will arrange investments in accordance with your instructions, subject to the following conditions:
- 10.2.1
  We will permit any investment to be held under your SIPP that appears on the current Schedule of Allowable Investments, which we may amend from time to time. You will be responsible for ensuring that your investment choices fall within the Schedule of Allowable Investments. You should refer to the current version before making any investment decisions;
- 10.2.2
  The investment must not constitute or result in an Unauthorised Payment or taxable property charge or an unacceptable liability or risk to us;
- 10.2.3
  In general, we have sole discretion as to whether any asset can be held under your SIPP and reserve the right to dispose of any assets that:
- (a)
  are deemed by us to be an unacceptable asset or unlawful;
- (b)
  would impose tax or other costs on us or expose us to liabilities;
- (c)
  are no longer a type allowed by HMRC or the FCA or one which could give rise to Unauthorised Payment tax charges; or
- (d)
  must be disposed of to comply with a court order.
- In any such event, we will not be liable for loss or costs incurred in disposing of assets;
- 10.2.4
  You must ensure that there are always sufficient funds available in your SIPP to effect your chosen investment and to cover fees;
- 10.2.5
  No deals may be placed with any investment provider (e.g. discretionary manager, stockbroker etc) until they are in receipt of cleared funds from your SIPP; and
- 10.2.6
  All investments held for your SIPP are to be registered in the Trustee’s name, as trustee of the Scheme, or may be held on the Trustee’s behalf by an investment manager, nominee or third party custodian (being a party that holds investments on behalf of your SIPP). The investments will be designated as an investment of your SIPP.
10.3
We may from time to time have an approved panel of investment providers, including discretionary fund managers and execution-only providers, who have passed our due diligence requirements and have agreed an application process with us. Where applicable, a list of any such providers is on our website or the mobile app and is subject to change from time to time. We do not endorse the capacity of the investment provider to provide investment services of a particular quality or that meet your particular requirements nor do we endorse their financial or regulatory status. Your adviser should conduct his/her own due diligence before recommending a panel investment provider to you, and if you do not have an adviser, you should make all relevant enquiries yourself before selecting your panel investment provider.
10.4
We will not be responsible for advice given by an investment manager or any exercise of discretion by an investment manager.
10.5
Any investment income or capital gains arising from the assets held under your SIPP will, after deduction of costs and any liabilities, be credited to, and form part of, your Member Fund.
10.6
We may dispose, or direct the investment manager to dispose, of any investment without consultation with you or your prior agreement if:
- 10.6.1
  in our reasonable opinion, continued retention of such investment would be unlawful or would impose tax or other costs on us or the Trustee or your SIPP or expose us or the Trustee or your SIPP to liabilities which in each case your SIPP may not be able to meet;
- 10.6.2
  in our reasonable opinion, the investment needs to be disposed of to return any tax or any relevant part of a pension contribution (in accordance with Section 17), to pay costs or liabilities (in accordance with Sections 13 and 16), to meet any tax liability (in accordance with Section 16) or to restore any minimum balance required to be held in the Cash Asset Line;
- 10.6.3
  the investment is not or is no longer a type allowed by the current Schedule of Allowable Investments;
- 10.6.4
  disposal of the investment is required by the terms of any applicable agreement, for example a co-ownership agreement;
- 10.6.5
  required to comply with the terms of a court order; or
- 10.6.6
  required following your death in order to secure death benefits.
10.7
Neither we nor the Trustee will be responsible for any loss (including loss of profit) in relation to, or reduction in value of any investment:
- 10.7.1
  acquired at your request, unless such loss or reduction results from fraud, wilful misconduct, negligence or breach of regulatory duty on our part, or the fraud, wilful misconduct, negligence or breach of regulatory duty of the Trustee or any of our employees or agents;
- 10.7.2
  not acquired or not disposed of in accordance with our rights under these Terms;
- 10.7.3
  disposed of in accordance with these Terms, unless such loss or reduction results from fraud, wilful misconduct, negligence or breach of regulatory duty by us, or the fraud, wilful misconduct, negligence or breach of regulatory duty of any of our employees or agents; or
- 10.7.4
  which results from any action or omission of any nature whatsoever by any investment manager or by any nominee, banker, custodian or other person providing services to any investment manager or to the Trustee or to you or us.
10.8
Certain investments may result in your SIPP holding Taxable Property either directly or indirectly. Where Taxable Property is held as part of your SIPP, HMRC may apply tax charges on both your SIPP and you personally. If these tax charges arise in respect of an investment purchased for your SIPP, such tax charge will be met by your SIPP or from you personally as the case may be.
10.9
If any investment transaction is to be carried out between your SIPP and you or any Connected Party, the transaction must take place on arm’s length, commercial market terms and in accordance with any other requirements of HMRC.
10.10
The assets held under your SIPP will be valued from time to time as required and at frequencies necessary to meet prevailing FCA guidelines in respect of our capital adequacy requirements. Valuations of certain assets will incur valuation fees from third party valuers and we may charge a fee for obtaining valuations. These fees and costs will be settled from your Member Fund.

11.1
The fees payable to us in respect of your SIPP are set out in our Schedule of Fees, as amended from time to time, which is downloadable from our website or the mobile app. You agree to pay us the fees set out in the Schedule of Fees. All fees are exclusive of VAT, which is payable in addition. Fees may be subject to increases. We will give you as much notice as is reasonably practicable of such increases and in accordance with FCA Rules.
11.2
Our fees will be deducted from your Member Fund in line with our Schedule of Fees as soon as they are incurred or become due. Our fees will be settled from cash in the Cash Asset Line or (if you have one) from your current account. All other costs and liabilities which we are entitled to charge to your SIPP will be deducted from the Cash Asset Line.
11.3
For the effective operation of your SIPP, we may require a minimum balance in your Cash Asset Line, as appropriate to meet the regular transactions in your SIPP (e.g. drawdown income payments and fees). You must ensure that there are sufficient funds in your Cash Asset Line to meet any expected single or regular payments (including our fees). If there are insufficient funds in your Cash Asset Line to make such payments, including payment of any benefits to you, we may not make the payment.
11.4
We reserve the right to charge interest from 30 days after the date of a request from us for payment of extra cash or instructions to sell assets held under your SIPP, at a rate of 2% above the base rate from time to time of Barclays Bank plc on the balance outstanding. All costs associated with the recovery of the fees will be invoiced to your SIPP.
11.5
Where we appoint professional advisers or other duly authorised representatives in relation to your SIPP, any agreements will be on such terms as to remuneration, liability or otherwise as we think fit and will include terms:
- 11.5.1
  allowing us to pay their fees and expenses from your Member Fund, unless you pay them on behalf of your SIPP; and
- 11.5.2
  limiting our liability and the Trustee’s liability to the professional adviser or other duly authorised representatives to the value of assets under your SIPP.
11.6
All tax charges under the Act, including (but not limited to) a Lifetime Allowance Charge, will be deducted from your SIPP.

12.1
All instructions to us must be made by the secure online facility or via the mobile app. If any instructions are unclear, we may request clarification from you or your financial adviser or your other duly authorised representative before proceeding. We will not be responsible for any losses caused by delays resulting from seeking such clarification.
12.2
Any notice or communication that we give to you under these Terms will be in writing and sent by email or the secure online facility or via the mobile app. If a communication is sent by email before 5pm on a business day, it will be deemed to be served on that day. Otherwise, a communication sent by email will be deemed to be served on the next business day after it is sent. Any communication which we provide to you is not intended to be relied upon by any third parties.
12.3
We may cease to give effect to, or (where applicable) continue to give effect to, your instructions in relation to your SIPP if:
- 12.3.1
  it is shown, to our satisfaction, that by reason of your physical disability or mental incapacity you are unable to manage your own affairs (the written opinion of a qualified medical practitioner may be accepted by us as conclusive evidence of this fact);
- 12.3.2
  we are notified of your death (we may, but need not, refuse to accept any such notification unless it is accompanied by a certified copy of the death certificate);
- 12.3.3
  that acting on your instructions would or may in our opinion breach any applicable law, regulation or requirement or result in an Unauthorised Payment; or
- 12.3.4
  the occurrence of some event or circumstance is brought to our attention which means (in our opinion) it is inappropriate to continue to follow your instructions.
12.4
You must notify us immediately of any changes concerning your SIPP membership, including payment of contributions which do not attract tax relief, a change to your personal details (including your contact details) or if you cease to be a UK resident.
12.5
You must comply with legal and regulatory requirements to notify us if you do any of the following under another Registered Pension Scheme:
- 10.6.1
  you take more than the maximum income limit from a capped drawdown fund; and/or
- 10.6.2
  you take drawdown pension from a flexi-access drawdown fund; and/or
- 10.6.3
  you take Uncrystallised Withdrawal.
12.6
You must notify us of the relevant event within 91 days of the date that you take Flexible Benefits, or within 91 days of the date that you receive a statement from the scheme administrator of the other Registered Pension Scheme confirming that the event has happened. You must also notify, within the same timescale, all other Registered Pension Schemes of which you are a member if you take Flexible Benefits from your SIPP.

13.1
A Cash Asset Line will be set up for your SIPP to hold the cash in your Member Fund. On receipt, all monies are deposited in the Cash Asset Line. We will operate the Cash Asset Line on behalf of the Trustee and we will be the authorised signatory.
13.2
Cash held within your Cash Asset Line will be pooled with other Members’ cash and deposited by the Trustee in a non-interest bearing bank account operated by an authorised bank (the SIPP Bank Account). The bank we have appointed may change from time to time. Your holding in the SIPP Bank Account will not earn any interest, however we reserve the right to change this in the future, at our absolute discretion, and we will notify you of any such changes.
13.3
Your cash is held in the SIPP Bank Account as client money, in accordance with FCA requirements, and we treat our members as ‘retail clients’ for the purposes of these requirements. We keep records and perform daily reconciliations which enable us to identify your funds in the SIPP Bank Account at any time.Your cash is held in the SIPP Bank Account as client money, in accordance with FCA requirements, and we treat our members as ‘retail clients’ for the purposes of these requirements. We keep records and perform daily reconciliations which enable us to identify your funds in the SIPP Bank Account at any time.
13.4
We reserve the right to change our chosen bank or our banking arrangements at any time. If we do so, we will provide the relevant details on our website or the mobile app and will give you written notice if we change our chosen bank.

14.1
Neither we nor the Trustee shall be liable:
- 14.1.1
  to you for any claims, costs, expenses, losses, liability, default or delay arising in relation to your SIPP and its underlying investments; or
- 14.1.2
  for any tax charge or Unauthorised Payment made by or in respect of your SIPP. If any such charge is incurred or any such payment is made, we shall be entitled to take steps to recover any fees, charges or expenses incurred by us in respect of such liability in accordance with paragraph 14.3 below, unless this is caused by our wilful neglect, wilful default or fraud.
14.2
Neither we nor the Trustee shall be liable for losses or incur any liability arising out of or in relation to any of the following:
- 14.2.1
  you or your advisers or other duly authorised representative providing us with insufficient or inaccurate data or information, or delays on the part of you or your advisers or other duly authorised representative in providing the required data or information;
- 14.2.2
  any acts or omissions by any discretionary fund manager, nominee or custodian company or any third party you may use to assist you in making investments;
- 14.2.3
  the performance of investments and assets held in your SIPP, any loss on such investments and assets and/or any resulting consequential loss to you (for example the loss of the opportunity to invest in another investment);
- 14.2.4
  a failure to perform our role or delay in performing our obligations under these Terms if the failure or delay results from war, riot, terrorism, fire, flood or other natural disaster, a pandemic, strikes or industrial action, cyber-attack on our computer systems, failure of our computer equipment or systems, or any other cause beyond our reasonable control;
- 14.2.5
  any Unauthorised Payment or tax charge incurred under the Act or otherwise in relation to your SIPP;
- 14.2.6
  any transactions in relation to your SIPP made by your adviser or other duly authorised representative or appointed power of attorney (or any other person you have generally authorised to deal with your SIPP) that are placed without your authority;
- 14.2.7
  the performance of any third party involved in providing you with products or services, including the issuer or provider of any investment and any broker, dealing partner, market maker or other counterparty used to execute a transaction;
- 14.2.8
  not being able to place any instructions due to the unavailability of our services, including our online and telephone systems and mobile app, as a result of maintenance or upgrade of systems (and we may not always be able to give you advance notice when such maintenance or upgrade will take place); or
- 14.2.9
  where we are unable to carry out your instructions after we have accepted them for whatever reason (other than our negligence, fraud or deliberate default).
14.3
We may recover from your Member Fund any fees and charges that may be made and any claims, costs, expenses or losses that may arise in respect of:
- 14.3.1
  your investment decisions or any loss on the investments in your SIPP;
- 14.3.2
  any tax charge, whether resulting from an Unauthorised Payment or otherwise;
- 14.3.3
  us taking or defending legal proceedings in relation to your SIPP; and
- 14.3.4
  corrective action taken by us following an act or failure to act by you which is prohibited by legislation and/or regulation.
14.4
Sufficient cash must be available in the Cash Asset Line to meet the charges, costs, claims or expenses applicable to your SIPP. If there is insufficient cash, and you do not provide more cash or instruct us which assets to sell within 30 days of a request from us, we will take steps to recover the charges, or any costs, claims or expenses incurred by us from your SIPP or other investment products. If any such amounts are not recoverable from the funds in your SIPP, we may take all steps that we consider reasonable to realise assets in order to recover overdue fees and/or to recover the shortfall from you personally. You agree to indemnify us and the Trustee in respect of such amounts.
14.5
Nothing in these Terms will exclude or limit our liability for wilful default or fraud, fraudulent misrepresentation or fraudulent concealment, or any other loss or liability that cannot be excluded or limited by law, including liability for death or personal injury caused by our negligence.
14.6
Where you carry out an act in relation to your SIPP that is prohibited by law or regulation or which is or may be deemed to be an Unauthorised Payment, we will, without your consent, take such action as is necessary to correct the act. In this regard, you agree to fully indemnify the Trustee and Scheme Administrator in respect of all costs, claims, demands and expenses incurred, whether from your SIPP or your personal assets.
14.7
We will not be liable for any indirect or consequential loss or damage or any loss or damage that is not reasonably foreseeable.
14.8
In all cases, the Trustee’s liability shall be limited to the available assets as held solely in its capacity as Trustee of your SIPP.
14.9
You agree to indemnify the Trustee, Scheme Administrator and us, their employees and agents (the Indemnified Parties) against all costs, claims, expenses, tax charges, demands and losses whatsoever (Liabilities) that the Indemnified Parties may suffer or incur in exercising their duties, responsibilities and functions in relation to your SIPP, except where that Liability arises from the negligence, fraud or wilful default of the Indemnified Parties.

15.1
You have the right to cancel the membership of your SIPP within 30 days of receipt by us of your Application Form and a notice will be sent to you to explain your rights (the Cancellation Rights Notice). If you wish to cancel your SIPP, you will need to provide written notice to us within 30 days of receipt of the Cancellation Rights Notice.
15.2
To ensure that you are not disadvantaged by exercising your right to cancel, during the 30-day cancellation period, funds can only be invested in your Cash Asset Line.
15.3
If you cancel your SIPP within the first 30 days, any contributions made will be returned. If there are any funds that have been transferred into your SIPP from another pension scheme during this period, we will attempt to return these to the transferring pension scheme, however we cannot guarantee that this will be possible because not all pension providers will accept the return of funds. The value of the underlying investments will be returned to the transferring pension scheme, which may be lower than the amount that was originally transferred. We will deduct all reasonable costs and charges incurred in doing this. If the original pension provider will not accept the funds back, we will allow you to transfer out of the SIPP free of charge if you have cancelled the membership within 30 days.
15.4
You have the option to waive your rights to cancellation, so that investment transactions may be made immediately in relation to your SIPP. However, if you subsequently choose to cancel your SIPP, fees will be payable for the administration work carried out, closure of the Cash Asset Line and any transfer out that you instruct us to make. If you have made an investment under your SIPP within the first 30 days, you will receive back the value of the underlying investment, which may be less than the initial amount that you invested. You do not have the right to cancel any investments unless the investment itself has a specific cancellation period.
15.5
A 30 day cancellation period also applies the first time you choose to take retirement benefits from your SIPP. A notice will be sent to you which will allow you 30 days from the date we make any payment to you to change your mind. If you decide to cancel your decision to take benefits, any lump sums or drawdown income paid to you will need to be returned to the SIPP. The returned funds will remain in cash until you instruct us how you want them invested.

16.1
You may close your SIPP at any time by giving at least 30 days' written notice to us. Any fees payable by you on closure are shown in the Schedule of Fees and fees for administering your SIPP will continue to be payable until it is closed.
16.2
You may only close your SIPP if you cease to have benefits under the SIPP or if there is a transfer of the entirety of your Member Fund under your SIPP to another Registered Pension Scheme or QROPS or on a winding up of the Scheme, in accordance with the Trust Deed and Rules.
16.3
We may cease to provide the Services to you and close your SIPP if:
- 16.3.1
  there are no monies held under your SIPP for a period of at least 30 days; or
- 16.3.2
  you fail to comply with these Terms. In this case, we will give you an opportunity to rectify the breach and a further 30 days’ notice of closure; or
- 16.3.3
  at any time, by giving a minimum of 30 days' notice to you.
16.4
We will then carry out activities necessary to close your SIPP, including arranging payment of your Member Fund to another scheme, which we may do without your consent. Fees may be payable by you for carrying out these activities, in accordance with the fees set out in the Schedule of Fees, and all other fees will continue to be payable.
16.5
Termination will not be complete until all payments and benefits have been made, to you or your beneficiaries, in the event of your death, from your Member Fund and fees will continue to be invoiced in respect of Services rendered until termination and closure of your SIPP has been completed.

17.1
By giving you 30 days’ written notice (or such other notice period as we reasonably can), we may close the Scheme to new members and/or cease accepting contributions from existing members of the Scheme.
17.2
We will notify you of your rights and options in these circumstances. Where it is necessary to transfer your SIPP to an alternative Registered Pension Scheme, your consent will not be required, although you will be given an option to make a transfer to a Registered Pension Scheme of your choosing, within a specified timeframe.

20.1
We will not disclose any confidential information relating to you to a third party without your prior written consent except:
- 20.1.1
  disclosures made at your specific request;
- 20.1.2
  to your professional advisers and your financial adviser or your other duly authorised representative, as necessary;
- 20.1.3
  to the Pensions Regulator, FCA, another regulator, HMRC or any government or other authority or as party to legal proceedings;
- 20.1.4
  as may be required by law or a court of competent jurisdiction; and/or
- 20.1.5
  as otherwise set out in these Terms.

22.1
We have legal obligations regarding the detection, reporting and prevention of fraud, money laundering and terrorist activity. If a person or entity is proposing to pay money to your SIPP, we will take required steps to verify their identity. We will do this electronically where we are able to and we may use an online referencing agency for this purpose.
22.2
You must provide satisfactory documents to evidence and verify your identity and the identity of any person who will pay money to your SIPP. Such documents are required to be provided to us before we can establish your SIPP, act in accordance with any instructions from you and/or accept the payment of money into your SIPP. Clause 12 of Schedule 6 applies in addition to these Terms.

23.1
If you want to make a complaint about us or our Services provided under these Terms, please make this in writing by email or by post to us in the first instance, by using the contact details
below:
[ ]
23.2
We will provide to you on request a copy of our complaints handling procedure.
23.3
If you are not satisfied with our response, you can refer your complaint to The Pensions Advisory Service or Financial Ombudsman Service (FOS):
- Financial Ombudsman Service
  Exchange Tower
  London E14 9SR
  Phone: 0800 023 4567
  ‍
  Further information can be found at:
  complaint.info@financial-ombudsman.org.uk
23.4
If your complaint is about the administration of your SIPP and you are not satisfied with our response, The Pensions Advisory Service (TPAS) can provide you with free help and advice. Its service is provided through a network of local advisers. If it is unable to resolve your complaint you can then refer it to The Pensions Ombudsman which deals with complaints and disputes regarding the administration of pension schemes. They are independent and act as an impartial adjudicator. These organisations can be contacted at:
- Website: pensionsadvisoryservice.org.uk
  Email address: enquiries@pensionsadvisoryservice.org.uk
  Telephone number: 0800 011 3797120
  Holborn, London EC1N 2TD
- Website: pensions-ombudsman.org.uk
  Email address: enquiries@pensions-ombudsman.org.uk
  Telephone number: 0800 917 448710
  South Colonnade, Canary Wharf, London E14 4PU

25.1
If any provision or part-provision of these Terms is or becomes invalid, illegal or unenforceable, or is judged by any court to be void or unenforceable, it shall be deemed modified to the minimum extent necessary to make it valid, legal and enforceable. If such modification is not possible, the relevant provision or part-provision shall be deemed deleted. Any modification to or deletion of a provision or part-provision under this clause shall not affect the validity and enforceability of the rest of the Terms.

27.1
The Contract shall constitute the entire agreement between the parties in relation to its subject matter, and shall supersede all previous agreements, arrangements and understandings between the parties in respect of that subject matter.
27.2
Neither party will have any remedy in respect of any misrepresentation (whether written or oral) made to it upon which it relied in entering into the Contract.
27.3
The provisions of this clause 27 are subject to clause 14 (Limitations and exclusion of Liability).

29.1
In these Terms, unless the context otherwise requires: the singular includes the plural and vice versa; references to any statute or regulations shall be references to such statute, or regulations as from time to time amended, re-enacted or replaced from time to time and any reference to the FCA and rules made by it shall include its successor as regulator and rules made by the successor as regulator. References to any law, statute or statutory provision will include any subordinate legislation made under any of them, as modified, amended and/or replaced and in force from time to time.
29.2
Definitions

Act
means the Finance Act 2004;
Annual Allowance
(within the meaning of section 228 of the Act) means the maximum that you, your employer or a third party can pay into all your Registered Pension Schemes in a pension input period and gain tax relief;
Cash Asset Line
means the designated cash asset line set up for the purposes of your SIPP inaccordance with Section 15 (Cash Asset Line and SIPP Bank Account) of these Terms;
Connected Party
means a person (individual or company) who is connected with you because the person falls within the definition of a connected person in section 993 of the Income Tax Act 2007. This includes, for example, (amongst others) your spouse, registered civil partner, children, parents, siblings and other direct descendants and ancestors of you and your spouse or registered civil partner and a company that you control (either on your own or together with persons connected with you);
Discretionary Trust
means the basis under which lump sum death benefits are paid out by us at our discretion. We may decide entirely at our discretion who should receive such a lump sum, and how much, from the list of beneficiaries described in the Trust Deed and Rules. We will take into consideration any Expression of Wishes, but we are not obliged to follow it in exercising our discretion;
Expression of Wishes
means an expression of your wishes in respect of whom you would like to receive death benefits from your SIPP when you die;
FCA
means the Financial Conduct Authority;
Flexible Benefits
(within the meaning of section 74 of the Pension Schemes Act 2015) means where a Member chooses to access their money purchase pension savings by taking a flexi accessdrawdown pension, Uncrystallised Withdrawal or by designating a flexi-access drawdown fund;
HMRC
means HM Revenue & Customs;
Ill-Health Condition
(within the meaning of paragraph 1 of schedule 28 of the Act) means that the Scheme Administrator has received evidence from a registered medical practitioner that the Member is (and will continue to be) incapable of carrying on his occupation because of physical or mental impairment, and that they have in fact ceased to carry on their occupation;
Lifetime Allowance
(within the meaning of section 218 of the Act) means the amount of pension saving an individual may accumulate within all Registered Pension Schemes during their lifetime which benefits from tax relief. You may have a personal lifetime allowance that is different from the Standard Lifetime Allowance;
Lifetime Allowance Charge
(within the meaning of section 214 of the Act) means the tax charge that arises where total pension saving by an individual under all their Registered Pension Schemes exceeds the Lifetime Allowance;
Member
means a person who has applied for and been accepted as a member of the Scheme;
Member Fund
has the same meaning as in the Trust Deed and Rules and means, in summary, an account and fund under your SIPP to which all monies paid into your SIPP will be credited and benefits will be paid from it and from which we may deduct fees, charges, expenses and taxes in accordance with the Trust Deed and Rules and these Terms. Cash in your Cash Asset Line is part of your Member Fund;
MPAA
means the Money Purchase Annual Allowance, the reduced Annual Allowance that applies to Members who have accessed Flexible Benefits;
Pension Date
means the date applied to your SIPP reflecting the date on which we start, at your request, paying you a benefit. A Pension Date cannot be earlier than age 55 unless: you have a Protected Pension Age in relation to a transfer in of your benefits to your SIPP on a non-voluntary basis and your Pension Date relates to all the assets in your SIPP set up for that transfer; or the Ill-Health Condition has been met;
Protected Pension Age
(within the meaning of paragraph 21(2) of schedule 36 of the Act) means where a Member meets certain requirements set by HMRC for transitional protection and is entitled to receive benefits before age 55 without them being treated as Unauthorised Payments;
QROPS
(within the meaning of section 169 of the Act) means a ‘qualifying recognised overseas pension scheme’, a pension scheme based outside the UK that HMRC recognises as eligible to receive transfers from Registered Pension Schemes without a tax penalty. To be a QROPS, a scheme must meet various prescribed conditions;
Registered Pension Scheme
(within the meaning of section 150(2) of the Act) is a pension scheme registered with HMRC in order to qualify for certain tax reliefs;
Scheme
means the WealthKernel SIPP;
Services
means the services provided by us to you in accordance with Section 5 of these Terms;
Serious Ill-Health Lump Sum
means the proceeds paid out from your Member Fund after we receive evidence from a registered medical practitioner that you are expected to live for less than one year;
SIPP (and the term “your SIPP”)
means the self-invested personal pension under the Scheme of which you are a Member and in which you have invested. References to your SIPP include any investments or benefits held within your Member Fund;
SIPP Bank Account
means a common bank account in our name with our chosen bank, which is used collectively for all Members, in which cash is held as client money in accordance with FCA requirements and is protected by CASS 7 and the FCA client money rules and regulations. Further details relating to the SIPP Bank Account, including any compensation entitlements under the FSCS, are set out in the Key Features Document;
Standard Lifetime Allowance
(within the meaning of section 218 of the Act) means the maximum amount of saving that an individual may make in a Registered Pension Scheme without incurring a tax charge, currently £1,073,100 but subject to change by the Government from time to time;
Taxable Property
(within the meaning of paragraph 6 of schedule 29A of the Act) means assets that attract a tax charge if held directly or indirectly (i.e. as part of certain investments, unless they are covered by specific exemptions) by your SIPP, which includes residential property and tangible moveable assets, for example cars, art or stamps;
Terms
means these terms and conditions, as amended from time to time;
Transitional Rights
means HMRC’s rules for transitional protection of rights built up before 6 April 2006, when they simplified the pensions tax regime from that date;
Trust Deed and Rules
means these terms and conditions, as amended from time to time;
Trustee
means WealthKernel Trustees Limited (company number 12685292);
Unauthorised Payment
(within the meaning of section 160 of the Act) means a payment that is not authorised by HMRC and is made from the Scheme or your SIPP or another Registered Pension Scheme to (or in respect of) a Member or to (or in respect of) an employer and is subject to tax charges under the Act;
Uncrystallised Withdrawal
means a withdrawal made from your Member Fund as an Uncrystallised Funds Pension Lump Sum (UFPLS) under the Act;
WealthKernel
means WealthKernel Limited.

The Financial Services Compensation Scheme (FSCS) is the UK’s statutory compensation scheme for customers of authorised financial services firms. It provides protection to eligible customers if a firm is unable to meet its financial obligations.
The Pension Operator for your The Wealthkernel SIPP is Wealthkernel Limited (company number 09686970) and the Trustee is Wealthkernel Trustees Limited (company number 12685292).
This Key Features Document shows you the main points about The Wealthkernel SIPP. Please read it carefully and keep it with your The Wealthkernel SIPP documents.
Neither Tenant name or Wealthkernel Limited provide investment advice as this is an execution only service. We do provide information about pension and investments, but this document is provided solely to enable you to make your own pension and investment decisions and must not be treated as a personal recommendation. If, after considering these risks, you have any doubts about the suitability of The Wealthkernel SIPP or if you need advice then you should seek advice from a suitably qualified financial adviser.

It is your responsibility to understand the features, benefits and risks of the Wealthkernel SIPP; this is to ensure it meets your expectations.
You must ensure that any contributions you make do not exceed the relevant pension contribution limits.
You must provide us with the information we require on set up of your Wealthkernel SIPP and you agree to be bound by Tenant Name Limited’s Terms & Conditions and Wealthkernel Limited Terms & Conditions.
You agree to pay the charges as set out in the Wealthkernel SIPP.
You agree to inform Tenant Nameif you are no longer eligible for tax relief.

Below are outlined risks associated with saving for retirement through a pension plan such as the Wealthkernel SIPP. Some of the risks below refer to the performance of the Plans selected by you in your Wealthkernel SIPP. Remember that you are responsible for the investment decisions. In many instances, the Plan you invest in will also have key information documents that outline the specific risks applicable to that investment and we recommend you read these as well as this document.
The value of your Wealthkernel SIPP and the pension income from it at your chosen pension age cannot be guaranteed as it will depend on future pension transfers, contributions and investment performance up to the point that you start taking your pension income. All investing into stocks and shares products should be regarded as being for the longer-term. The value of your investments can go up and down and you may get back less than you invest.
Your pension income, pension commencement lump sum and future transfer values may be lower than shown in the accompanying illustration.
This could happen for reasons such as:
- Changes to annuity rates
- Investment performance is lower than illustrated
- You start taking your pension income earlier than your chosen pension age
- Tax rules changes
- Charges are higher than shown in the illustration
Please note you could suffer a tax liability if contributions are funded from a pension commencement lump sum received from a registered pension scheme.
There may be a delay in receiving benefits if some of your investments cannot be sold quickly.
You have a right to cancel your Wealthkernel SIPP within the first 30 days. Where you have invested during this period and you exercise your right to cancel then the amount returned will be the amount realised less any costs associated with the investment and subsequent disinvestment.
Whilst the Wealthkernel SIPP can accept transfers from other pension schemes, not all transfers may be suitable. The Wealthkernel SIPP will not accept any Defined Benefit pensions or safeguarded benefit transfers or any transfers of non-standard assets. For all transfers you are responsible, with the help of a financial adviser if necessary, for ensuring that the transfer of your other benefits and / or assets to the Wealthkernel SIPP is suitable for you.

About The Wealthkernel SIPP
What is the Wealthkernel SIPP?
The Wealthkernel SIPP is a personal pension plan that allows you to save for retirement in a tax-efficient and flexible way. The benefits you can receive are subject to UK pensions legislation and the provisions of the Wealthkernel SIPP Scheme Rules as well as the Terms & Conditions. The legislation includes rules about limits on the amount of contributions that can qualify for tax relief, the earliest age you can take benefits, and limits on what those benefits can be without incurring tax penalties, including the amount that can be taken as tax-free cash.
The Wealthkernel SIPP does not currently offer pension withdrawals. In order to do so, you will need to transfer away to an appropriate provider.
Who is The Wealthkernel SIPP for?
The Wealthkernel SIPP does not currently offer pension withdrawals. In order to do so, you will need to transfer away to an appropriate provider.
- Combine pensions in one place.
- Save regularly but flexibly for their retirement.
- Make investment decisions about their pension assets themselves.
- Understand that growth is not guaranteed.
- Wish to manage your Wealthkernel SIPP via the Tenant Name App/Website and accept Wealthkernel’s Terms and Conditions.
If you are in any doubt as to whether the Wealthkernel SIPP is right for you, then you should consider speaking to a financial adviser. Further information on pension schemes is available on HMRC's website. Stakeholder Pension schemes are generally available and may meet your needs as well.
Can I open a Wealthkernel SIPP?
You can join and transfer existing pension policies into the Wealthkernel SIPP if you are resident in the UK.
What are the Scheme Rules?
The Scheme Rules are the legal documents that have established the Scheme under which the Wealthkernel SIPP. They comprise the trust deed and the rules governing the operation of the Scheme. The trust deed appoints the Trustee, which is Wealthkernel Trustees Limited, and the Scheme Operator, which is Wealthkernel Limited.
Is this a Stakeholder pension scheme?
No. Stakeholder pension schemes are a specific form of pension that must meet Government minimum standards relating to contributions, charges and provision of a default investment fund. Stakeholder schemes are generally available and it is for you to consider, with the assistance of a financial adviser, if required, whether one might meet your needs.
Will my Wealthkernel SIPP have its own bank account?
This type of pension plan does not have a separate bank account for each pension plan but operates under a pooled bank account which is run by the scheme administrator, Wealthkernel Limited on behalf of the Trustee. Money paid into or out of your Wealthkernel SIPP will go via this account. Any uninvested cash will also be held in this account.
What will be the value of my Wealthkernel SIPP?
The final value of your Wealthkernel SIPP will depend on how much is paid in, how long you invest for, the charges paid, and how well the investments perform. You will be sent an annual statement showing the performance of your investments along with other factors that affect the value, such as charges. You can also access the value of your Wealthkernel SIPP anytime via the Tenant App/Website.

Age on opening
Transfer-In Value
Monthly Contribution
£10,000
£50,000
£100,000
£250,000
£50
£200
£50
£200
£50
£200
£50
£200
25
Value
£47,800
£130,000
£135,000
£219,000
£248,000
£334,000
£605,000
£695,000
Income
£2,050
£5,570
£5,800
£9,410
£10,600
£14,300
£25,900
£29,800
30
Value
£42,300
£133,000
£121,000
£193,000
£223,000
£297,000
£543,000
£619,000
Income
£1,840
£4,920
£5,290
£8,420
£9,710
£12,900
£23,600
£26,900
35
Value
£37,200
£97,400
£109,000
£170,000
£201,000
£263,000
£489,000
£552,000
Income
£1,630
£4,290
£4,830
£7,490
£8,860
£11,500
£21,500
£24,300
40
Value
£32,300
£82,500
£98,400
£148,000
£181,000
£232,000
£440,000
£492,000
Income
£1,440
£3,680
£4,390
£6,630
£8,090
£10,300
£19,600
£21,900
45
Value
£27,800
£68,200
£88,000
£128,000
£163,000
£203,000
£396,000
£438,000
Income
£1,260
£3,090
£3,990
£5,820
£7,400
£9,240
£17,900
£19,800
30
Value
£23,500
£54,500
£78,300
£109,000
£146,000
£177,000
£356,000
£388,000
Income
£1,080
£2,500
£3,600
£5,030
£6,760
£8,180
£16,400
£17,800

The figures in the above table are based on the following assumptions:
- Medium annual growth of 2.90%
- An inflation rate of 2% per year
- Tenant’s Annual Management charge of 1%, including all fund charges.
- Retirement at age 67
How much pension income will I get?
transfer out to do so. However, this type of pension plan usually allows you, once you reach minimum pension age (currently age 55), to draw as much or as little of your income as you like, when you like, along with offering different benefit options as explained under the `Benefits summary’ section below. How much pension income you will get therefore depends on your choices and many variable factors such as income tax, the value of your Wealthkernel SIPP and investment performance.
What are the charges?
Tenant Name charges you a monthly subscription fee, and an annual management fee which is based on a percentage of the value of your Wealthkernel SIPP and is deducted monthly from your Wealthkernel SIPP. The details of these fees are set out in the Fees Guide which you can find in the Tenant App and on the Tenant website and which you should read alongside this Key Features Document.
These fees include the cost of administering your Wealthkernel SIPP which in broad terms covers such things as setting up your Wealthkernel SIPP, the ongoing administration, regulatory reporting and for carrying out certain transactions.
Please remember that asset managers may also charge for the purchase, sale and management of the assets held within your SIPP. You should refer to their separate key information documents for details.
Contributions
How can I contribute to my Wealthkernel SIPP?
You can make single one-off or regular contributions to your Wealthkernel SIPP, paid directly from your bank account. We are unable to accept employer contributions. Making regular contributions will help increase the value of your Wealthkernel SIPP (depending on Investment performance) but you are not committed to maintaining them.
In the future, you may be able to make contributions through the App. If you choose to stop or decrease the value of your contributions this will reduce the value of your Wealthkernel SIPP at retirement.
Contributions can be made by bank transfer, direct debit, or any other method we may advise of from time to time.
Are there any minimum contribution limits?
The minimum contribution is £1.00 The minimum investment is £1.00.
What is the maximum contribution limit for my Wealthkernel SIPP?
You are free to contribute as much as you like, subject to the annual HMRC limits.
Personal contributions that qualify for tax relief can be paid into your Wealthkernel SIPP. This means you can normally pay up to £3,600 (including tax relief) per year regardless of your employment status, as long as you are resident in the UK.
If you have UK earnings chargeable to income tax you can contribute up to 100% of these earnings. However, if your total contributions (including tax relief) to all registered pension schemes exceed an amount known as the Annual Allowance you will be liable for a tax charge on the excess, unless you can use up (carry forward) any left-over annual allowance from the three previous tax years.
What is the Annual allowance?
Your annual pension contributions on which you can receive tax relief are subject to a maximum amount known as the Annual Allowance, which is set each year by the Government. For the tax year to 5th April 2026, the Annual Allowance is £60,000. The Annual Allowance applies as a total limit across all of your registered pension schemes in a tax year.
It covers:
- Your contributions into pension arrangements in that year.
- Employer contributions to pension arrangements made in respect of you in that year.
- Certain increases in the value of retirement benefits you may have in a defined benefit pension scheme.
The Annual Allowance does not include the amount of transfers from other pension arrangements. They do not receive extra tax relief, so there is no upper limit on them. The Annual Allowance does not apply in a tax year in which severe ill-health benefit conditions are met or death occurs.
If you are a high earner i.e. have ‘adjusted income’ of over £260,000 and `threshold income’ of over £200,000 then your Annual Allowance will be subject to a tapered reduction of £2 for every £1 of earnings above £260,000 up to £360,000 subject to a minimum annual allowance of £10,000.
Do I get tax relief on my contributions?
We will claim any basic rate tax relief you are entitled to from HMRC. All personal contributions (whether you are employed or self-employed) are payable net of basic rate tax (20% for 2025/26 tax year).
- E.g. If you pay a net contribution of £80 then we will reclaim £20 from HMRC and credit this amount to your SIPP once it has been received. This will normally be received within 11 weeks.
If you pay income tax at a rate higher than the basic rate, you can claim additional tax relief via your tax return or by contacting HMRC if you don’t complete a tax return.
You must tell us within 30 days if you are no longer entitled to tax relief on your contributions.
Can I transfer existing pension investments to you?
You can transfer your existing pension arrangements into your Wealthkernel SIPP, unless:
- It is a “Final Salary” or “Defined Benefit” arrangement;
- It has specific terms that allow you to purchase an annuity or other form of retirement income at a pre-defined or advantageous rate
- it is subject to a penalty in the form of a reduction in value applied by your existing pension provider if you were to transfer it to your Wealthkernel SIPP.
The transfer to your Wealthkernel SIPP will be made by cash or existing stocks and shares; depending on those stocks and shares meeting the requirements of the SIPP rules and of the Wealthkernel Platform.
Before transferring your existing pension to the Wealthkernel SIPP, you should consider the following:
- If you will lose benefits available with your current scheme (e.g. retirement before the age of 55, more than 25% taken as tax-free cash, guaranteed death benefits greater than the value of the pension)
- Whether your current provider will apply exit penalties or other costs to transfer your pension
- How the ongoing costs and charges with your current provider compare to ongoing costs and charges with the Wealthkernel SIPP
- How the investment options with your current provider compare to the investment options available with the Wealthkernel SIPP
- Potential ‘small pot’ pension benefits such as not triggering the money purchase annual allowance on withdrawal
- By selling your assets to transfer them, you will be ‘out of the market’ until the money is reinvested, so you could be affected by rises or falls in the market when reinvesting back into stock or units.
If you are unsure about how to make this decision, please seek independent financial advice.
Can I transfer my Wealthkernel SIPP to another provider?
Yes, you can transfer out your Wealthkernel SIPP at any time.
You can transfer your Wealthkernel SIPP in the form of cash by selling assets before affecting the transfer. Or you can transfer the assets as they are, providing your new SIPP / Pension manager will accept them.
What assets am I able to invest in?
All customers can choose between a selection of Plans, available in the Tenant app. You can invest only in the range of funds offered via the Tenant App.
What fund information do we provide?
We will provide you with a Key Investor Information Document or the Fund fact sheet in addition to a summary of information on the Plan. The KIID provides you with details of the objective, the risk and reward profile, special risk factors and charges associated with the fund you are thinking of investing in. The content and format of a KIID is prescribed by the Financial Conduct Authority. A KIID must be provided to anyone who invests in a mutual fund, such as a OEIC or Unit Trust, prior to investment. Fund managers must produce a KIID for all collective investment schemes. The charges in the KIID are unique to the Fund it represents and do not include Wealthkernel or Wealthkernel SIPP charges.
The Fund fact sheet gives you information of the fund, its performance and its underlying holdings.
Do I pay tax on the holdings within my Wealthkernel SIPP?
Growth in the value of your Wealthkernel SIPP is free of UK income and Capital Gains tax. Dividends received will be paid gross and not be part of your annual dividend allowance and this is the same as any interest received, this will not count towards your personal savings allowance.
How do I obtain a valuation of my Wealthkernel SIPP Pension?
You can obtain a valuation at any time through the Tenant App.
Can I withdraw money from my Wealthkernel SIPP?
Only in exceptional circumstances. Your Pension is designed to allow you to grow your pension related savings. Once you are eligible to take payments from your pension you may freely transfer your Pension to any suitable arrangement to manage your retirement income.
However, in the case of death or being eligible for an early withdrawal (see below), you may take payments from your Pension.
Early withdrawal If you are diagnosed with serious ill-health or a terminal illness that means your life expectancy is less than 12 months, and you have not yet started to take benefits, you can choose to take your pension benefits as a lump sum. Taking your benefits early may affect the value of your benefits. If you take benefits earlier than you originally intended, the level of the benefits you can take may be lower than expected and may not meet your needs in retirement.
If you die before age 75 Your Pension’s full cash value will be used to provide benefits for your spouse/civil partner, dependants, family members or other beneficiaries nominated by you for this purpose.
The Trustees will decide who will receive benefits at their absolute discretion. However, it will take into account any wishes you have expressed through the completion of a death benefit expression of wish. You may complete a new nomination at any time.
A beneficiary can elect to receive their benefit as a lump sum. Alternatively, they may be able to use it to purchase a dependant's annuity, or a Flexi-access dependant's pension with a provider of their choosing.
Payments on death are normally free of any income or inheritance tax but we cannot guarantee that this will be the case. You should consult an adviser if you are unsure.
Any amount of the fund over your personal Lifetime Allowance may be subject to a tax charge. This will be determined by your personal representatives.
If you do not leave a surviving spouse/civil partner or dependants then the value of your fund may be paid to a charity nominated by you for this purpose.
Any funds paid to a charity will be exempt from tax. If you die after the age of 75 any subsequent payment of death benefits will not be subject to the Lifetime Allowance.
How is banking and administration carried out?
Any cash you send will be held in a Client Money bank account held with a UK bank in accordance with the CASS rules.
Administration is carried out by Wealthkernel Limited.
Is my Pension protected?
The Wealthkernel SIPP is covered by the Financial Services Compensation scheme (FSCS) to the value of £85,000. Additionally, if any of the banks which are used for depositing cash are declared in default, each individual is entitled to 100% of the first £85,000 in total, in compensation for losses across all their deposits with that bank. In the unlikely event that you were to suffer financial loss directly because a fund manager of a Unit Trust or Open Ended Investment Company became insolvent you will be able to claim under the investment business section of the FSCS. Each FCA authorised UK based fund manager will qualify for the investment element of the FSCS. If a fund manager becomes insolvent and is unable to return your money you will be protected for 100% of the first £85,000 held with it.
the first £85,000 held with it. Further information about the compensation arrangements is available from the Financial Services Compensation Scheme at www.fscs.org.uk
How do I complain?
In the first instance please contact the Tenant support team via the Tenant app. If you are not satisfied with the response you may refer your complaint to the:
The Pensions Ombudsman, 10 South Colonnade, Canary Wharf, London, E14 4PU Tel No: 0800 917 4487.
Important notes:
The information in this Key Features Document is provided based on our understanding of current law, practice and taxation which may be subject to change.
Full details of the legally binding contract between you and us (Tenant Name) and Wealthkernel Limited) are included in our Terms and Conditions which you should have been provided with and which are available upon request.
The law of England and Wales will apply in all legal disputes

Service

Fee

General account services

Maintaining the account

£4.99 per month or £49.99 per year.

Payments (excluding cards)

Standing Orders

£0

Sending Money in the UK

£0 if sent in the UK using FPS

Receiving Money in the UK

£0

Cards and cash

Cash Withdrawal in GBP in the UK

£1 per ATM withdrawal

Cash Withdrawal outside of the UK in any other currency

£1.50 plus 1% of withdrawal amount

Replacement Card

£5.00 including printing, shipping and deactivation of old cards.

Overdrafts and related services

Arranged Overdraft

Not Applicable

Unarranged Overdraft

Not Applicable

Other services

Direct Debit

Not Applicable

Cashing/Cancelling a cheque

Not Applicable

Rejected a payment due to lack of funds

£0

Legal

Yeeld Privacy Policy

Yeeld Cookie Policy

Yeeld Companion Wallet and Visa Consumer Debit Mastercard Terms and Conditions

Yeeld Companion Investment Terms and Conditions

WealthKernel Terms and Conditions -ISA Terms

WealthKernel Terms and Conditions - GIA Terms

WealthKernel Terms and Conditions - SIPP Terms

Key Features of the Wealthkernel SIPP

Fee Information Document

FSCS Protection