1. Introduction
Evermind Wealth (“We,” “Us,” or “Our”) provides a secure, purpose-built platform to support wealth managers and Independent Financial Advisors (IFAs) in managing administrative workflows efficiently and responsibly.
Our platform offers tools for:
Letters of Authority (LoA): Generate, send, and track LoAs to obtain client authorisations for retrieving information from financial providers.
Data Retrieval and Storage: Facilitate secure requests for client pension and investment information and organise provider responses for Advisor review.
Meeting Management: Upload audio recordings or text notes of client meetings to generate summaries, extract follow-up tasks, and streamline workflows.
AI Assistant: Ask questions about meeting content and client records to retrieve specific details and improve task management.
Workflow Organisation: Track follow-up tasks and manage administrative priorities effectively.
Our Role and Limitations:
We act as an administrative support platform and do not perform any regulated activities. Specifically:
- We do not provide financial, regulatory, legal, or tax advice.
- We do not hold, manage, or process client money or financial instruments.
- We do not execute trades, manage investments, or influence financial decisions.
While our services fall outside the scope of MiFID II regulation, we operate with a strong commitment to data protection, transparency, and compliance readiness, including alignment with ISO 27001 standards.
2. MiFID II Applicability
Our services do not constitute regulated activities under MiFID II for the following reasons:
2.1 No Investment Services:
- We do not provide investment advice, manage client portfolios, or execute transactions.
2.2 No Client Money or Assets:
- We do not hold, manage, or transfer client funds or financial instruments.
2.3 Administrative Role Only:
- Our platform serves as an administrative tool, including meeting summarisation, task organisation, and AI-driven insights, to support the workflows of wealth managers and IFAs.
While MiFID II does not apply, we adhere to best practices in compliance, data security, and transparency to maintain the highest levels of operational integrity.
3. Data Protection and UK GDPR Compliance
We handle sensitive personal and financial data as a data processor for wealth managers and IFAs, adhering to UK GDPR principles:
3.1 Lawfulness, Fairness, and Transparency:
- Client data is processed only with explicit consent obtained by the Advisor.
- Our privacy policy clearly outlines how data is collected, stored, and shared.
3.2 Purpose Limitation:
- Data is collected and used solely for platform functionalities, including information retrieval, meeting summarisation, AI queries, and workflow organisation.
3.3 Data Minimisation:
- Only data necessary to perform requested services is collected and stored.
3.4 Accuracy:
- Advisors are responsible for ensuring the accuracy and completeness of data submitted to our platform.
3.5 Retention and Deletion:
- Data is retained only as long as necessary to fulfill contractual obligations or meet legal requirements. Upon request, all data is securely deleted from our systems.
3.6 ISO 27001 Readiness:
- We are actively progressing toward ISO 27001 certification, implementing robust controls and policies to safeguard sensitive data.
4. AI Assistant Compliance
4.1 AI Functionality:
The AI assistant processes meeting summaries, client records, and organisational data to provide:
- Answers to Advisor queries about past meetings or client details.
- Summaries of key meeting points.
- Task management assistance.
4.2 Data Security:
- All interactions with the AI assistant are encrypted and securely logged for compliance purposes.
4.3 Limitations:
- The AI assistant does not provide financial advice, offer recommendations, or analyse investment strategies.
- Responses are based solely on information already present in the platform, and Advisors are responsible for reviewing and validating AI-generated outputs.
4.4 Client Consent:
- Advisors must ensure client consent is obtained before uploading or processing client information via the AI assistant.
5. eIDAS Compliance (Electronic Signatures)
- We facilitate electronic signatures for Letters of Authority in compliance with the Electronic Identification, Authentication, and Trust Services (eIDAS) Regulation.
5.1 Legal Validity:
- Our electronic signature process meets the requirements for Advanced Electronic Signatures (AES), ensuring authenticity and tamper-proof integrity.
5.2 User Responsibility:
- Wealth managers and IFAs must confirm that the signatures align with their specific legal and regulatory needs.
6. Financial Promotions Compliance
We ensure that our marketing materials comply with FCA rules on financial promotions by:
6.1 Avoiding Financial Advice:
- We clearly communicate that our platform does not provide financial, regulatory, or investment advice.
6.2 Transparency:
- All promotional materials accurately describe our platform’s role as an administrative tool for wealth managers and IFAs.
6.3 No Misleading Claims:
- We do not imply that our platform influences financial decisions or outcomes.
7. Liability and Responsibilities
7.1 Advisor Responsibility:
- Advisors are responsible for ensuring data accuracy, securing client consent, and complying with their regulatory obligations.
7.2 Third-Party Information:
- We are not liable for errors, omissions, or delays caused by third-party providers (e.g., pension companies).
7.3 Platform Use:
- Our platform is provided “as is.” While we strive for reliable operation, we do not guarantee uninterrupted or error-free service.
8. Governance and Review
- This policy is reviewed annually or whenever there are significant changes to our business model, regulatory landscape, or service offerings. Updates will be communicated to all stakeholders.
9. Contact Information
For compliance-related inquiries, please contact:
Compliance Officer
Evermind Wealth
Ormeau Labs
18 Ormeau Avenue
Belfast
BT2 8HS