Elite 360 Ltd - Membership, Concierge & Card Services

Effective 8 September 2026  |  Company No. 15047746  |  Registered in England & Wales  |  Jurisdiction: UK GDPR

 

This Privacy Policy describes how Elite 360 Ltd ("Elite 360", "we", "us" or "our") collects, uses, and protects your personal information when you use our website (www.elite360.uk), our mobile application ("the App"), enquire about or use our concierge, membership, and card services, or otherwise interact with us. By using our website, App, or services, you agree to the collection and use of information as described below.

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1. Interpretation & Definitions

Company ("Elite 360", "we", "us", "our") refers to Elite 360 Ltd, 168 City Road, Cardiff, Wales, CF24 3JE, registered in England and Wales under company number 15047746.

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Website refers to www.elite360.uk. App refers to the Elite 360 mobile application, available on iOS and Android.

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Service refers to the Website, the App, and all concierge, lifestyle management, membership, and card/wallet services provided by Elite 360.

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Identity Verification Provider means the third-party service Elite 360 engages to carry out identity verification (KYC) and anti-money laundering (AML) checks required to issue and manage your card and account.

 

Card Services Provider means the third-party service Elite 360 engages to issue, personalise, and process transactions on your virtual or physical card.

 

2. Personal Data We Collect

 

2.1 Information you provide directly

• Full name, title, and preferred name

• Date of birth and nationality

• Email address, phone number, and mobile country code

• Postal / delivery address

• Company name and job title, where applicable

• Membership preferences, lifestyle preferences, and personal requests you share with us

 

2.2 Identity verification (KYC) data

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IDENTITY VERIFICATION (KYC) DATA

To comply with anti-money-laundering and financial services regulations, before issuing a card or account we must verify your identity. This involves:

• Government-issued identification (e.g. passport, driving licence)

• Proof of address documents

• A live selfie photograph, captured via your device's camera, matched against your ID document

• The verification outcome and any associated compliance reference codes

 

Verification is carried out through our Identity Verification Provider via a secure, hosted page opened within the App. Elite 360 does not independently retain copies of your raw ID documents beyond what is necessary to facilitate this verification and meet our own regulatory record-keeping duties.

 

2.3 Card and account data

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CARD AND ACCOUNT DATA

Once your identity is verified, we and our Card Services Provider process:

• Your card balance and available funds

• Transaction history - merchant, amount, date, and status

• Virtual and/or physical card details (masked card number, expiry, card status)

• Wallet top-up and transfer activity

 

Full card numbers, PINs, and CVV are handled directly within our Card Services Provider’s secure infrastructure and are never visible to or stored by Elite 360’s own systems in unmasked form.

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2.4 App permissions

• Camera - used solely during identity verification, so you can photograph your ID document and take a selfie. Not accessed at any other time.

• Face ID / fingerprint - used solely to unlock a device login credential stored on your own device - see Section 11.

 

2.5 One-time passcodes (OTP)

For login and certain sensitive actions - such as changing your password or PIN - we send a one-time passcode to your registered email address. Each code is time-limited and single-use.

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2.6 Information collected automatically

When you use our App or website, we may automatically collect your IP address, device identifiers, browser type and version, operating system, and pages or screens visited.

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2.7 Cookies (website)

Our website uses Essential, Functionality, and Analytics cookies. You can control or disable cookies through your browser settings; disabling some may affect functionality.

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3. How We Use Your Data

• Verify your identity and comply with AML / KYC regulatory obligations

• Issue, manage, and process transactions on your card and account

• Respond to your enquiries and manage your membership

• Deliver concierge services, travel arrangements, and other requests you make

• Communicate with you regarding your account, requests, or transactions

• Send updates or marketing communications, where you have consented

• Improve our website, App, and member experience

• Detect and prevent fraud, misuse, or unlawful activity

• Comply with our legal and regulatory obligations

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4. Legal Basis for Processing (UK GDPR, Article 6)

• Contract - processing necessary to provide your card, account, and membership services

• Legal Obligation - identity verification and AML checks are required under UK financial services and anti-money-laundering regulations

• Legitimate Interests - fraud prevention, security, and service improvement, where not overridden by your rights

• Consent - where you have given explicit consent, such as for marketing communications

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5. Discretion & Confidentiality

Elite 360 operates with the highest standard of discretion. Personal and financial information you share with us is treated as strictly confidential and is not disclosed to third parties except as necessary to verify your identity, process your card or account, fulfil your requests, or as described in this Privacy Policy. Our team members are bound by confidentiality obligations and are trained to handle member information with the utmost care.

 

6. Sharing Your Data

We share personal information only with:

• Identity Verification Providers - to carry out KYC/AML checks required to issue your card and account

• Card Services Providers - to issue, personalise, and process transactions on your card

• Professional Advisers - legal, financial, or compliance advisers where necessary

• Business Transfers - in the event of a merger, acquisition, or sale of assets; you will be notified beforehand

• Legal Requirements - where required by law, court order, or regulatory / AML authority

• With Your Consent - for any other purpose you have explicitly agreed to

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We do not sell your personal data to third parties.

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7. Data Retention

We retain personal data, including KYC verification records, for as long as necessary to provide your account and card services and to satisfy our legal and regulatory record-keeping obligations — including AML requirements, which may require retention for a defined period after account closure. You may request deletion of other personal data at any time, subject to these legal retention obligations.

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8. International Data Transfers

Elite 360 is based in the United Kingdom. If your personal data is transferred outside the UK or EEA — including to our Identity Verification or Card Services Providers — we ensure appropriate safeguards are in place in accordance with UK data protection law.

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9. Your Rights

Under UK GDPR, you have the following rights over your personal data: You have the right of access, meaning you can request a copy of the personal data we hold about you; rectification, meaning you can request correction of inaccurate or incomplete data; and erasure, meaning you can request deletion of your data, subject to our AML/KYC record-keeping duties. You may also request restriction of how we use your data, exercise your right to portability by receiving your data in a structured, machine-readable format, or object to processing based on legitimate interests or direct marketing. Where processing relies on your consent, you may withdraw consent at any time.

 

To exercise any of these rights, contact us at info@elite360.uk. We will respond within one month. You may also lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.

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10. Security

We employ appropriate technical and organisational measures, including secure transmission to our Identity Verification and Card Services Providers, to protect your information against unauthorised access, loss, or disclosure. No method of transmission or storage is entirely secure, and we cannot guarantee absolute security.

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11. Biometric Login

DEVICE-LEVEL ONLY

If you enable Face ID or fingerprint login in the App, this is handled entirely by your device’s own operating system and secure hardware — your raw biometric data is never transmitted to, seen by, or stored by Elite 360.

Instead, a successful biometric match on your device unlocks a separate, randomly-generated login credential stored securely on that device, which the App uses to sign you in without re-entering your password. Logging in on a new device automatically revokes this credential on your previous device.

 

12. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us and we will take steps to remove it.

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13. Third-Party Links

Our website and App may contain links to third-party websites or services. We are not responsible for the privacy practices or content of those sites, and encourage you to review their policies.

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14. Marketing Communications

If you have opted in to receive marketing communications, we will contact you with relevant updates about Elite 360 services. You may unsubscribe at any time via the link in any email or by contacting info@elite360.uk.

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15. Changes to This Policy

We may update this Privacy Policy from time to time; the "Effective" date at the top will be revised accordingly. Where changes are significant, we will notify you by email or a prominent notice within the App or website.

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16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data:

Elite 360 Ltd
Email: info@elite360.uk
Phone: +44 (0)29 2030 4411
Website: www.elite360.uk

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17. Account Deletion

If you wish to delete your account or data please follow the instructions here: Click Here