Last updated 23 September 2019

Earthworm sets out the conditions under which we may process any information that we collect from you, or you provide to us. The policy covers information that could potentially identify you (‘personal information’) and any information which may not. In the context of this notice ‘process’ means collect, store, transfer, use or otherwise act on information. If you are dissatisfied with any part of this privacy policy, your only recourse is to leave our website immediately.

Earthworm takes seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.

This policy explains how we collect, process and store your personal data. It also describes how we keep your data secure and private.

The data controller responsible for this website is Earthworm Limited, Company Number: 10927642. If you have any questions in relation to our use of your details, please write to us at or at 115P Olympic Avenue, Milton Park, Milton, Abingdon OX14 4SA.

If you want to know your rights and our obligations to you regarding the processing and control of your personal data, please read the information provided at

We confirm, unless specified within this policy, that Earthworm does not share, sell, or disclose to a third party, any information collected through our website.

Type of information we hold

In order to provide our services (such as the administration of accounts and making investments) certain information is collected, including:

    • Contact information, including basic personal information
    • Data to help identify clients and prevent fraud
    • Transactional information
    • Financial information
    • Information relating to business contacts such as professional advisers
    • Publicly available data relating to investee companies, including directors and shareholders
    • Personal information relating to directors in order to reach investment decisions.

Unless permission has been given we will not collect personal data from our website.

Information is collected on (but not limited to) clients (existing and prospective) as well as business contacts and company directors/shareholders.

How we get the information and why we have it

Personal information can be collected in a number of ways, including:

    • Signing up for a mailing list
    • By entering into an agreement with us to provide investment services meaning we will also collect financial information
    • Telephone calls and emails
    • From third parties such as financial advisers or credit reference platforms
    • Other sources as authorised by you.

Your personal information privacy is protected by law and the legal basis for processing your information is outlined below:

    • To ensure we can deliver our services and manage client relationships
    • To ensure we can fulfil our operational functions
    • To manage risk and prevent criminal activity by complying with legal requirements
    • The protection of your vital interests.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept the use of cookies, Earthworm will not use them for your visit except to record that you have not consented to their use for any other purpose.

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. 

Cookies can be turned off, however this may restrict access to certain parts of our website. You can find out how to turn off cookies here.

We also use Google Analytics to help us see how our website is used and interacted with. Information relating to these cookies can be found here.

Our website may contain hyperlinks, however you should be aware that any data you pass to external websites are not covered by this policy therefore you should review each site’s privacy policy separately.

What we do with the information

Personal information is never sold or traded however in some instances we share data with our suppliers. This information will only be used for a specific purpose and agreements will be in place to ensure the protection of your data.

Examples of the types of third party that we may share your data with are listed below:

    • Regulatory or governmental agencies such as HMRC or the FCA
    • Entities that help us meet our legal obligations or enable us to perform services in our contract with you, such as credit reference agencies or software providers
    • Other entities such as financial advisers that introduced you to us.

We may contact you if you are an existing client or have opted to receive our marketing communications however you may opt out of this at any time by contacting us by email or post using the details at the start of this policy.

We only store data for as long as is required (such as to perform our contractual or legal obligations or to keep records of transactions) and it is regularly reviewed and deleted.

How we store your information

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and encrypt any data you give us. When information is transferred between us, you can check this is done by using SSL by looking for a closed padlock symbol or another trust mark in your browser’s URL bar or toolbar. We cannot, however, guarantee the security of data transmitted from your own device(s) and therefore any online communications such as email or via our website are entirely at your own risk.

Earthworm colleagues also receive data protection training and follow stringent procedures to protect personal data.

Personal information is only stored within the European Economic Area however we also use a U.S. based service called MailChimp to send some email communications. MailChimp is operated by The Rocket Science Group LLP who are part of the EU-US Privacy Shield Scheme that ensures steps have been taken to keep data adequately protected. Information relating to MailChimp’s participation in this scheme can be found here. Details about the Privacy Shield Scheme can also be found here.

Earthworm’s website is hosted by Brixly and registered with GoDaddy. Brixly’s privacy policy can be located here and GoDaddy’s policy is found here.

Your data protection rights

You have a number of legal rights in relation to the control of your personal information:

    • Right of access: you may obtain copies of your personal data either electronically or by letter
    • Right of objection: you may object to us using your personal data
    • Right to be forgotten: you can ask us to remove your data from our records and cease the use of your personal data however we can only comply if there is no legal reason for us to hold the data
    • Right of rectification: you may request for missing or inaccurate data to be corrected.

If you would like further information on your rights, email us at .


If you have a complaint regarding our privacy policy, the way we manage your personal information, our website or our services, please email us at or write to us at Complaints Department, Earthworm, 115P Olympic Avenue, Milton Park, Milton, Abingdon OX14 4SA.

If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO) at

Changes to this privacy policy

We may occasionally make changes to this privacy policy. Following any changes, the date at the top of the privacy policy will be updated. If any change allows for the broader access to, or sharing of data, such changes will only apply to data collected after the date of the updated privacy policy.

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