Privacy Policy

Last updated: 13/11/2025

This privacy policy sets out how Leaton Wealth, a registered trade name of Leaton VOF, uses and protects the personal information we collect about you. We process your data in accordance with the General Data Protection Regulation (GDPR) and Article 8(3) of the Charter of Fundamental Rights of the EU.

1. Who We Are

Leaton Wealth
Registered Trade Name of Leaton VOF
Registered Office: Stooktstraat 215, 9600 Ronse, Belgium
Company Registration Number: 0731.766.119
VAT Number: BE0731766119

For data protection matters, Leaton Wealth acts as the Data Controller.
Contact: datacontroller@leatonwealth.com
General Data Protection Contact: privacy@leatonwealth.com

Leaton Wealth operates primarily within Belgium.

2. What Information Do We Collect?

We collect personal information when you engage us for financial or wealth advisory services. This may include:

Personal identification details
Contact information
Financial details and investment information
Information relating to your objectives and circumstances
Records of communication or interactions with us
Details provided through voluntary surveys or feedback
Website usage data via cookies

In certain cases, we may collect special categories of personal data, such as health information, when required for the provision of our services.

3. Why Do We Collect and Use Your Personal Data?

Our primary legal basis for processing your personal data is the performance of our contract with you.

We require this information to:

Provide financial advice and related services
Make suitable recommendations
Fulfil legal, regulatory, and compliance obligations
Maintain accurate client records
Provide ongoing support and account administration

Where special category data is necessary, we will obtain your explicit consent.

4. How Will We Use Your Information?

We use your data to deliver the services for which you have engaged Leaton Wealth. This includes:

Providing financial advice and planning
Preparing recommendations
Managing your account and documents
Conducting regulatory compliance checks
Administering ongoing client relationships

5. Who Might We Share Your Information With?

We treat your information with the utmost confidentiality. We may share your data only when necessary to:

a) Provide our services

This may involve sharing information with:

Investment providers
Product and platform providers
Professional advisers (legal, tax, accountancy)
Compliance and audit partners
IT and secure data-processing partners

b) Meet regulatory or legal obligations

Including identity verification for anti-money laundering and financial crime prevention.

c) Support cross-border regulatory relationships

Because of our advisory structure, certain regulated activities are conducted with or through:

Brian Leather, appointed representative of:
Private Client Consultancy (PCC), a trading name of Efficient Frontiers SL
Registered Address: Calle Jardin Botanico, 23/24, La Cala de Mijas, Mijas Costa 29649
CIF: B42839589
Authorised by: Dirección General de Seguros y Fondos de Pensiones No J-3930

PCC is licensed to operate in:
Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Sweden, and the Netherlands under the freedom of services provision.

PCC acts as an Introducer to AQA Capital Ltd.
AQA Capital is regulated by the Malta Financial Services Authority (MFSA), Reg. Nr. C 70143, authorised as a UCITS and AIF management company and for MiFID services across the EU.

d) With your explicit consent

If you agree, we may notify you of other relevant services.

We do not share your data with companies outside our network for marketing purposes.

6. International Data Transfers

Where personal data must be transferred outside Belgium/EU—for example, for regulated investment activities—we ensure appropriate safeguarding measures such as:

GDPR-compliant data transfer agreements
Encryption and secure transmission
Transfers only to regulated entities or partners

7. How Long Do We Keep Your Data?

We retain personal data:

For as long as necessary to fulfil our contractual and regulatory obligations
For the minimum periods required under applicable Belgian and EU regulations
For longer where legally required or necessary to defend potential future claims
Never longer than 10 years after your death

You may request deletion of your data at any time, subject to regulatory retention requirements.

8. Your Rights Under GDPR

You have the right to:

Access your personal data
Request correction of inaccurate information
Request deletion (“right to be forgotten”)
Restrict or object to processing
Data portability
Withdraw consent at any time (where consent is the basis of processing)

Requests may be made via privacy@leatonwealth.com.

9. Marketing

We may send you information about our services if you have opted in.
You may opt out at any time by emailing privacy@leatonwealth.com.

We will not share your details with external third-party marketers.

10. Cookies

We use cookies to analyse website usage and improve user experience.
More information: https://www.allaboutcookies.org/

You can set your browser to refuse cookies, though some website features may not function properly.

11. Links to Other Websites

Our website may contain external links. This privacy policy applies only to Leaton Wealth. We encourage you to review the privacy policies of any linked sites.

12. Complaints

If you are unhappy with how we process your data, you may lodge a complaint with the supervisory authority:

Gegevensbeschermingsautoriteit (Belgian Data Protection Authority)
Rue de la Presse 35, 1000 Brussels
Website: https://www.dataprotectionauthority.be/

You may also contact us directly at privacy@leatonwealth.com.

13. Changes to This Policy

We review this privacy policy regularly. Any updates will be published on our website or communicated directly.

14. Contact Us

Leaton Wealth / Leaton VOF
Stooktstraat 215
9600 Ronse
Belgium

Email (General Privacy): privacy@leatonwealth.com
Email (Data Controller): datacontroller@leatonwealth.com

Regulatory Policy

Last updated: 13/11/2025

This Regulatory Policy explains the regulatory framework under which certain advisory and financial services connected to Leaton Wealth are conducted. It also outlines the authorisations, supervisory bodies, and licensing relevant to our appointed representatives and professional partners.

1. Advisory Structure and Regulatory Oversight

Certain regulated activities associated with Leaton Wealth are carried out through Brian Leather, who operates as an appointed representative of:

Private Client Consultancy (PCC)
A trading name of Efficient Frontiers SL
Registered Address: Calle Jardin Botanico, 23/24, La Cala de Mijas, Mijas Costa 29649, Spain
CIF: B42839589
Authorised by: Dirección General de Seguros y Fondos de Pensiones
Licence Number: J-3930

Efficient Frontiers SL holds:

Obligatory Professional Indemnity Insurance with AIG Europe for regulated activity
Sufficient financial capacity in accordance with Spanish and EU law

2. Freedom of Services Provision (EU Passporting)

Private Client Consultancy (Efficient Frontiers SL) is licensed to operate under the freedom of services provision across multiple EU and EEA jurisdictions.

This includes:

PCC is additionally licensed to operate in Spain, where the principal regulation is governed.

3. Relationship with AQA Capital Ltd.

Private Client Consultancy (a trading name of Efficient Frontiers SL) acts as an Introducer to:

AQA Capital Ltd.
Authorised and regulated by the Malta Financial Services Authority (MFSA)
MFSA Registration Number: C 70143

AQA Capital is authorised to act as:

A UCITS Management Company
An AIF Management Company

In addition, AQA Capital provides MiFID (Markets in Financial Instruments Directive) services, including:

Discretionary portfolio management
Investment advisory services

AQA Capital is authorised to:

Offer services across all EU member states via the EU passport
Provide services to clients outside the EU, subject to applicable jurisdictional requirements

4. Investment Committee Membership

Mr. Andrew Oliver, representing the PCC Group, serves as an Investment Committee Member with AQA Capital.
In this capacity, he is involved in:

Portfolio management-related functions
Oversight of investment strategy
Supporting due diligence and investment governance processes

His involvement ensures adherence to regulatory standards and professional practices within AQA Capital’s investment framework.

5. Professional Standards and Compliance

All regulated activities conducted through the above entities follow:

Applicable EU financial services regulations
Local regulatory requirements in each jurisdiction
High standards of professional conduct, client protection, and compliance oversight
Strict adherence to due diligence and suitability assessment requirements

Leaton Wealth ensures that all associated advisers, entities, and partners operate within the boundaries of the legal and regulatory framework governing cross-border financial services.

6. Contact for Regulatory Matters

For questions regarding this Regulatory Policy or for further compliance-related information, please contact: