AYESHA OFORI LTD
Privacy Policy
Last updated May 2026 ·
This Privacy Policy explains how Ayesha Ofori Ltd collects, uses, stores and shares your personal data. It covers this website (ayeshaofori.com), all forms and sign-ups on the site, and the Wealth Circles programme. Please read it carefully.
Who We Are
This website and the Wealth Circles programme are operated by Ayesha Ofori Ltd, a company registered in England and Wales, trading as Ayesha Ofori, Femme & Fortune and Wealth Circles.
Registered office: 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom.
We are the data controller responsible for your personal data. We process personal data in accordance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and other applicable data protection legislation.
We have not appointed a Data Protection Officer as we are not required to do so under Article 37 of UK GDPR. For all data protection queries, please contact us at support@ayeshaofori.com.
This part of the Privacy Policy applies to anyone who visits ayeshaofori.com, signs up to our newsletter, submits a contact form, listens to the Femme & Fortune podcast via our website, or interacts with us online without joining Wealth Circles. If you are a Wealth Circles member, Part 2 also applies to you.
1. What Data We Collect from Website Visitors
We collect different types of data depending on how you interact with us.
2. How We Use This Data
We use the data collected from website visitors and subscribers to:
send our newsletter, Femme & Fortune updates and other email communications you have opted into
respond to your enquiry or application
administer and improve the website
understand how people use our content so we can improve it
comply with our legal obligations
We do not use website visitor data to build individual profiles, make automated decisions, or share with third parties for their own marketing purposes.
3. Newsletter and Email Marketing
If you sign up to our newsletter or opt in to email communications, we will send you updates from Ayesha Ofori, which may include the Femme & Fortune newsletter, investment insights, programme announcements and other content we think you will find relevant.
We rely on your consent to send marketing emails. You may unsubscribe at any time using the unsubscribe link in any email or by contacting us at support@ayeshaofori.com. Unsubscribing will not affect any other relationship you have with us.
We use a third party email service provider to send and manage email communications. Your name and email address are shared with this provider solely for this purpose, under a data processing agreement.
4. Cookies
We use cookies and similar technologies in accordance with the Privacy and Electronic Communications Regulations (PECR) and UK GDPR.
Strictly necessary cookies are required for the operation and security of the website and do not require consent. Non-essential cookies, including analytics and marketing cookies, are placed only where you have provided consent through our cookie banner. You may change your preferences at any time using the cookie settings tool on the website.
Further information about the specific cookies we use, their purposes and retention periods is available in our Cookie Notice.
5. How Long We Keep Your Data
We retain data collected from website visitors and subscribers for the following periods:
Newsletter subscriber data: retained for as long as you remain subscribed, plus a short period thereafter to process your unsubscribe request and maintain suppression records.
Contact form submissions: retained for up to two years to allow us to respond and maintain a record of communications.
Website analytics data: retained for up to 26 months in anonymised or aggregated form.
When data is no longer needed, we delete or anonymise it securely.
6. Third Party Services (Website)
We use the following third party services in connection with the website and newsletter. Each processes data in accordance with its own privacy policy:
Customer.io: for sending and managing newsletter and marketing emails. Customer.io processes data in accordance with its own privacy policy and under a data processing agreement with us.
Website analytics provider: for understanding website usage through anonymised and aggregated data.
Website hosting provider: for hosting and operating ayeshaofori.com.
We do not currently use retargeting pixels, advertising networks or social media tracking tools that share your data with third party advertisers without your consent.
This part applies to you if you have applied to join, paid for, or are participating in the Wealth Circles programme. Part 1 also continues to apply to your use of the website.
7. What Wealth Circles Is
Wealth Circles is an educational membership programme. It is not a regulated investment service and does not provide financial advice, investment advice, personal recommendations or suitability assessments.
The programme includes live group sessions, a personalised Wealth Profile questionnaire, personalised voice note feedback, access to a private community WhatsApp group, educational materials and workbooks. This part of the Privacy Policy explains how we handle the personal data collected through all of these activities.
8. What Data We Collect from Wealth Circles Members
We collect personal data directly from you when you apply to join Wealth Circles, make a payment, complete your Wealth Profile, participate in live sessions, or interact with us or other members.
We do not collect National Insurance numbers, identity documents, AML screening information or politically exposed person data. Wealth Circles is an educational programme and these checks are not required or conducted.
Where you voluntarily share personal information beyond what is specifically requested — for example, information about your health, family circumstances or other sensitive matters in your Wealth Profile — we will treat that information with the same care as all other data collected, and will use it only to personalise your programme experience.
9. The Wealth Profile
The Wealth Profile is a detailed questionnaire completed before the programme begins. It covers your financial position, goals, investing knowledge, risk attitude, life context and relationship with money.
We collect this information for two purposes, each with its own lawful basis:
Programme delivery (contract): We use your Wealth Profile to personalise your experience, record and deliver your voice note feedback, and ensure the programme content is relevant to your situation. This processing is necessary for the performance of your contract with us.
Research and insight (legitimate interests and compatible purpose): We use anonymised and aggregated data from Wealth Profiles, together with data from programme participation over time, to build insights into how high-earning women in the UK approach wealth building and investing. Our purpose is to develop the most accurate and comprehensive evidence base on women, money and investing in the UK. We rely on legitimate interests under Article 6(1)(f) UK GDPR and on compatible purpose analysis under Article 6(4) for this use.
Before we use your data for research purposes, we anonymise it so that no individual can be identified from any aggregated dataset. We never share identifiable Wealth Profile data with third parties for research purposes.
If you would prefer your anonymised data not to be included in aggregated research, you may opt out at any time by contacting us at support@ayeshaofori.com. Opting out will not affect your participation in the programme in any way.
10. Voice Note Feedback
As part of the programme, we record a personalised audio voice note providing feedback on your financial situation, gaps and areas of focus. This voice note is created by Ayesha Ofori based on the information you provide in your Wealth Profile.
The voice note is a personal data record. It contains financial analysis specific to you and is stored securely. It will not be shared with other programme participants or third parties. It will be delivered to you after the 14-day cooling-off period has elapsed and the programme start has been confirmed.
We retain voice notes for the duration of your membership and for six years following the end of our relationship, after which they are securely deleted.
11. WhatsApp Community Group
As part of the programme, you will be added to a private Wealth Circles WhatsApp group. This involves sharing your phone number with Meta Platforms Inc (WhatsApp’s parent company) and making your display name and profile visible to other group members.
You should be aware that:
WhatsApp is operated by Meta and is subject to Meta’s own terms of service and privacy policy
other group members will be able to see your display name, profile picture and any messages you send in the group
we do not control Meta’s processing of your data and are not responsible for it
you may leave the WhatsApp group at any time without affecting your membership
We ask all members to treat the WhatsApp group as a confidential space and not to share or screenshot content from the group without permission. We cannot guarantee the conduct of other members.
You will be added to the WhatsApp group from the confirmed programme start date, or after 14 days from the date of payment, whichever is earlier.
12. How We Use Wealth Circles Member Data
We use your personal data to:
provide and administer the Wealth Circles programme and membership
send you your Wealth Profile questionnaire and deliver your personalised voice note feedback
add you to the private Wealth Circles WhatsApp group
communicate with you about the programme, sessions and any changes
process your payment via Stripe
respond to questions, complaints or requests
build anonymised insights into how high-earning women in the UK approach wealth building and investing, as described in section 9
monitor, improve and develop our services
comply with our legal and regulatory obligations
detect and prevent fraud and misuse of our platform
13. Sharing Wealth Circles Member Data
We share personal data only where necessary to deliver the programme or comply with legal obligations. We do not sell your personal data.
We may share your data with:
Stripe Inc, our payment processor, for processing your membership fee
Zoom Video Communications Inc, for the delivery of live programme sessions
Meta Platforms Inc (WhatsApp), where you are added to the community group as described in section 11
cloud hosting and IT service providers who store or process data on our behalf under appropriate data processing agreements
professional advisers, including legal and accountancy advisers, where necessary
regulatory or law enforcement authorities where we are required to do so by law
We do not share your Wealth Profile data, voice notes or personal financial information with other programme participants, third party investment platforms, financial advisers or any commercial partners.
14. Data Retention (Wealth Circles)
We retain Wealth Circles member data for the following periods:
Wealth Profile questionnaires and voice note feedback: for the duration of your membership and for six years following the end of our relationship, then securely deleted.
Programme participation data (session attendance, community contributions, workbook submissions): for the duration of your membership and for six years thereafter.
Payment records: for six years in accordance with HMRC requirements.
Anonymised and aggregated research data derived from Wealth Profile responses: not subject to deletion as no individual can be identified from it.
When personal data is no longer required, we securely delete or anonymise it.
The following sections apply to all users of this website and all Wealth Circles members.
15. International Transfers
Some of our third party service providers, including Stripe, Zoom and Meta, may process your data outside the United Kingdom. Where this occurs, we ensure that appropriate safeguards are in place, including UK-approved International Data Transfer Agreements, Standard Contractual Clauses, or transfers to countries with an adequacy decision.
You may contact us at support@ayeshaofori.com for further information about the safeguards in place for any specific transfer.
16. Security
We implement appropriate technical and organisational measures to protect your personal data in accordance with Article 32 UK GDPR. These include:
encryption of data in transit using secure protocols
secure hosting environments with restricted access controls
role-based access permissions limiting access to authorised personnel only
confidentiality obligations for staff and contractors
contractual safeguards with third party service providers
monitoring and incident response procedures
While we take reasonable steps to protect your personal data, no transmission over the internet can be guaranteed to be completely secure.
17. Your Rights Under UK GDPR
You have the following rights in relation to your personal data:
Right of access: to request a copy of the personal data we hold about you.
Right to rectification: to request correction of inaccurate or incomplete data.
Right to erasure: to request deletion of your personal data in certain circumstances.
Right to restriction: to request that we limit how we use your data in certain circumstances.
Right to object: to object to processing based on legitimate interests, including the use of your anonymised data for research purposes. If you object to research use, we will exclude your data from aggregated datasets going forward.
Right to data portability: to receive your data in a structured, machine-readable format where processing is based on contract or consent.
Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of your rights, please contact us at support@ayeshaofori.com. We will respond within one month. We may ask for proof of identity before processing your request. In certain circumstances we may lawfully refuse or restrict your request and will explain our reasons if we do so.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO): Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Website: www.ico.org.uk. We would appreciate the opportunity to address your concerns before you contact the ICO.
18. Children
This website and the Wealth Circles programme are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If you believe we have inadvertently collected data from a minor, please contact us at support@ayeshaofori.com and we will delete it promptly.
19. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, services or legal requirements. The latest version will always be available on our website. Where changes materially affect how we use your data, we will notify you by email before they take effect.
This policy was last updated in May 2026.
20. Contact Us
If you have any questions about this Privacy Policy, how we handle your data, or wish to exercise any of your rights, please contact us at:
support@ayeshaofori.com
Ayesha Ofori Ltd, 71–75 Shelton Street, Covent Garden, London WC2H 9JQ.
Ayesha Ofori Ltd · Registered in England and Wales
