Terms of Business and Appendices

Gather International Ltd

September 2023


1.    Background

  1. This document details the general Terms of Business, which, together with individual appendices and any documents referred to herein, constitute the base terms for all Services provided by Gather International Limited “Gather” (company number 11842758). This document was updated in April 2023 and supersedes all previous agreements and versions
  2. Gather provides an investment platform that gives you access to curated portfolios featuring funds from world-leading asset managers which can be accessed via a mobile-based application.
  3.  Gather is not directly regulated by the FCA but is permitted to carry on certain services for which Sapphire Central Partners LLP accepts regulatory responsibility.
  4. Gather has entered into an agreement with Third Platform Services Limited (“TPS”), on behalf of ourselves and each of our clients, whereby TPS has agreed to provide clearing and settlement, safe custody and associated services for our clients subject to these Terms. TPS is a company registered in England and Wales (registered number 09588254), whose registered office address is at Birchin Court, 20 Birchin Lane, London, EC3V 9DU. TPS is authorised and regulated under number 717915 by the Financial Conduct Authority. The current terms and conditions of TPS and the principal terms of the agreement with them as it applies to our clients, including you, are set out or summarised in Appendix below.
  5. Gather may, from time to time, enter into agreements with other third parties as your agent and which bind you. This may include custody and trading services. We will only enter into such agreements with lawfully authorised companies and will inform you with at least 30 days’ notice before doing so. You may terminate this agreement within that 30-day period if you do not wish to be bound by any such agreements by emailing support@gatherinvesting.com. Absent such termination, you authorise us to enter into such agreements as your agent.

2.   General Terms

Introduction and Structure of these Terms

3.   Definitions and Interpretation

In these Terms, the following words shall have the corresponding meanings unless the context otherwise requires:

“1986 Act” means the Financial Services Act 1986 as updated from time to time.

“Applicable Laws” means the laws of England and all laws, enactments, regulations, directly applicable EU regulations, rules, regulatory guidance and regulatory authorisations, licences and permits which apply to the provision or the receipt of the Services, including FSMA, the 1986 Act, and the FCA Rules and the rules of any other relevant regulatory authority, exchange or clearing or settlement system applicable to business which we transact for you.

“APP” as the context requires, means our mobile applications which are available on iOS and Android operating systems. The current version of these mobile applications can be downloaded at https://apps.apple.com/ca/app/gather-investing/id1580423069 for iPhone and at https://play.google.com/store/apps/details?id=com.gatherinvesting.app for mobile devices running the Android operating system or such other mobile application(s) and/or website(s) as we may make available from time to time to enable you to access your Gather Account and receive the Gather Services

“Authorised Representative” as defined under the 1986 Act.

“Copyable Portfolio” by placing a copy order, you authorise us to automatically recreate this portfolio for you in your Gather account without any prior consultation, consent or approval. This will be done on a pro-rata basis with the same products and the same trading instructions (unless such action would be in contravention of Applicable Law)

“Business Day” means any day which is not a Saturday, Sunday or public or bank holiday in England.

“Contribution” means credits made to your Platform Product.

“Copy Investing” means investing in ISA Eligible Investments by copying the investment portfolio allocation and any future changes in that portfolio of other Gather Experts who invest on the Gather Platform.  Further details of Copy Investing are set out in Appendix 6.

“Dealing Day” is the day on which the Fund’s underlying equities, bonds or ETFs are traded on your behalf.

“ISA Eligible Investment” means any assets you can hold in an ISA.

“Event of Default” means the occurrence at any time with respect to you of any of the following: (a) you fail to make any payment due to us or to deliver any securities due to us (or agents used by us) or to perform any other obligation owed to us; (b) you fail to comply with any Applicable Law; (c) you become unable to pay your debts as they fall due or become insolvent or bankrupt or become the subject of any insolvency, bankruptcy or administration proceedings (under any Applicable Law); (d) a winding-up resolution is passed, or a winding-up or administration order is made in respect of you or a receiver, liquidator, administrator or similar official is appointed in respect of you or any of your property (under any Applicable Law); or (e)you commit a material breach of these Terms or any Appendix, which is not immediately remedied.

“FCA Rules” means the rules and regulations of the Financial Conduct Authority (or its successor) in the United Kingdom contained in the FCA’s handbook of rules and guidance (as may be amended and updated from time to time).

“Financial Conduct Authority” or “FCA” means the UK Financial Conduct Authority of 12 Endeavour Square, London E20 1JN, or any applicable successor body.

“Financial Ombudsman Service” or “FOS” The office to whom you may refer any complaint you have about the Services provided to you if we cannot resolve or settle your complaint (to your satisfaction) within eight weeks of the date you first make the complaint.

“Funds” means the collective investment schemes / exchange traded Funds that are made available to you from time to time for investment via the APP.

“Fund Management Charges” are fees levied by the managers of the Funds. These charges (and certain other expenses) are included in the Permitted Investments valuations; however, whilst you do not pay these charges directly, they will affect your overall return.

“Gather” means Gather International Limited, a company incorporated in England and Wales (company number 11842758) with its registered office at DNS House, 382 Kenton Road, Harrow, Middlesex, United Kingdom, HA3 8DP.

“Gather Account” means the account we will open for you, enabling you to invest through the APP, which allows us to provide the Services.

“Gather Agreement” means your agreement with Gather under these Terms.

“Gather Platform” or “Platform” is the App.

“Gather Services” means the Services that Gather will provide you pursuant to these Terms.

“GIA” means a General Investment Account.

“HMRC” means HM Revenue and Customs, the UK’s tax authority.

“Investment Album” means collections of investments grouped by their style of investments.

“Investment Playlist” means collections of investments that provide broad diversified exposure.

“Investment Profile” means our assessment of your investment knowledge and experience, investment objectives, risk tolerance, capacity for loss and financial situation, including whether you can financially bear losses consistent with your investment objective.

“ISA” means an Individual Savings Account, a tax-exempt savings scheme for individuals established under the ISA Regulations.

“ISA Regulations” the Individual Savings Account Regulations 1998, the Individual Savings Account (Amendment) Regulations 2007 and the related HM Revenue & Customs guidance notes for ISA managers, as amended and in force from time to time.

“ISA Terms” are the additional terms contained in the Appendix of these Terms, which will apply to you should you choose to hold your investments through an ISA.

“JISA” means a junior ISA

“Key Features” means one or more of the GIA, JISA, and ISA key features.

“Maintenance fee” is the percentage fee charged, based on the value of assets in your investment account, charged monthly.

“Order” means an instruction received by Gather to buy or sell investments within your Platform Product.

“Order Transmission Policy” means the policy set out in Appendix, which Gather has adopted with a view to ensuring that when Gather receives instructions from you to undertake an investment (via the APP) and transmits those instructions to execute it and does so with a view to achieving the best possible result for you in accordance with the FCA Rules.

“Permitted Investments” are the funds and other assets included in the Gather Portfolio.

“Permitted Withdrawal” means a withdrawal of the cash and/or investments held through your Gather Account, other than in respect of a JISA, if permitted by the ISA Regulations and the terms of the particular Platform Product.

“Platform fee” is the monthly fee for accessing the Gather platform.

“Gather Wrapper” means each and any as applicable in the context.

“Privacy Policy” means our privacy policy as updated and amended from time to time and available at www.GATHERINVESTING.com.

“Retail Client” has the meaning given by the FCA Rules.

“Services” means the Gather Portfolio and Gather Wrappers which can be accessed by a mobile-based app.

“Service Providers” means any Gather Services provided to you via our trusted third parties.

“SIPP” means a self-invested pension plan.

“Terms” means these Terms of Business and Appendices of Gather International Ltd as updated from time to time.

“Third Financial” means the investment platform division of TPS

“TPS” is Third Platform Services Limited

“Transfer Out” means, in relation to your ISA, a transfer of Platform Product ISA together with cash and/or investments to another ISA, as permitted by the ISA Regulations. In relation to your GIA, a transfer of your Platform Product GIA together with cash and/or investments to another dealing account.

“Website” means the content displayed on our website, available at www.gatherinvesting.com, and its sub-pages.

“We”, “our” or “us” means Gather; and

“You” or “your” means the recipient(s) of these Terms.

A reference in these Terms to a ‘Clause’, ‘Appendix’ or a ‘Schedule’ shall be construed as a reference to, respectively, a clause, appendix, or schedule of these Terms, unless the context requires otherwise. References in these Terms to any statute, statutory instrument, or Applicable Laws include any modification, amendment, extension, or re-enactment thereof. A reference in these Terms to a ‘document’ also includes electronic documents. References to persons include but are not restricted to bodies corporate, unincorporated associations and partnerships.

Where applicable, and unless the context requires otherwise, any term used in Agreement has the meaning given to it by the FCA Rules.

Clause headings in this Agreement are for ease of reference only.

4.   Commencement and Status of Your Agreement with Us

5.   Your Right to Cancel


6.   Complaints

By post: FINANCIAL OMBUDSMAN SERVICE, Exchange Tower, Harbour Exchange, London, E14 9SR

By telephone: 0800 023 4 567

By email: complaint.info@financial-ombudsman.org.uk

By completing a website enquiry form at: https://help.financial-ombudsman.org.uk/help/enquiries

You can find further information about the FOS on its website: www.financial-ombudsman.org.uk.

7.    Compensation

8.   Client Categorisation

9.   Instructions

  1. to do so might breach Applicable Law or any of our other legal duties; or
  2. to do so would damage our reputation; or
  3. you may be unable to settle any relevant transaction due to insufficient balance on your account; or
  4. we consider that you do not meet or have not provided sufficient evidence to demonstrate or confirm that you meet the eligibility criteria for investing in the relevant investment, whether arising from restrictions imposed by any Applicable Law, product providers or for any other reason.

10. Availability and Provision of Gather Services

  1. you to open your Gather Account, open your Gather Portfolio and manage your selected investments; and
  2. us to receive your instructions to transact in investments in accordance with the investment selections you have made through your Gather Account.
  3. for the provision of information about your Gather Account, Platform Product(s) and investments held (including the value of your Gather Portfolio); and
  4. us to provide the Gather Services to you in accordance with the Terms of the Gather Agreement, all Applicable Laws and the FCA Rules.

You acknowledge and agree that Gather will provide all Services to You in its capacity as an Authorised Representative of Sapphire (being the authorised firm) without Gather itself being authorised (pursuant to the 1986 Act). Gather will always act on the strict instructions and or supervision of Sapphire.

11. Selecting Instruments

12. Your Use of Our App

13. Fees and Other Charges for Gather Services

14. Opening Your Gather Account and Making Contributions

  1. You are aged 18 or over.
  2. You are a UK resident for tax purposes, and
  3. You are not a U.S Person.
  4. You agree to notify us immediately by email at: support@gatherinvesting.com if any of the above warranties cease to be correct.

15. Communications

  1. by post, at the last known postal address that we hold for you, will be deemed delivered and received by you 2 Business Days after posting unless otherwise specified. We will not accept any liability for postal delays; and
  2. by email or secure electronic message will be deemed delivered and received immediately upon sending.

16. Your Instructions via the App

  1. the sole exclusive owner of any account number allocated to you by Gather;
  2. you will be responsible for keeping safe and confidential the use of your username and password;
  3. we may rely on all orders and secure message instructions using your account number. You will be bound by any agreement entered into or expenses incurred on your behalf in reliance on such orders and secure message instructions.
  1. we reasonably believe that the security of your Gather Account or Platform Product has been compromised; and/or
  2. it is illegal or against any relevant rule or regulation for instructions to be sent to the Funds’ manager.
  3. If it’s in our reasonable opinion that such instructions for such investment would be unlawful

The above reasons are not exhaustive.

17. Your Information and Data Protection

  1. we may use your data including your contact details, your application details (but not banking details) and details of the services we provide you with and how you use them, to inform you about other similar products and Services that may be of interest to you; and
  2. if and to the extent that you have permitted us to do so, we may contact you by telephone (including automated calls), post, email and other electronic messages, such as short texts, with information, news and updates in relation to the Services and financial services of other selected partners.
  3. You can opt-out of receiving this marketing information at any time either in-app or by contacting support@gatherinvesting.com.
  1. delay the opening of your Gather Account; or
  2. return and cancel your application; or
  3. withhold from you the ability to trade or withdraw any cash funds until we have successfully verified your identity.

18. Withdrawals

19. The Gather Community and Information on the Gather Platform


  1. you must make sure that all content belongs to you or that you have a right to post that information, and that you do not violate the privacy rights, publicity rights, copyright, contract rights, or any other rights of any individual or make derogatory remarks regarding, defame or otherwise criticise any persons or entity. You shall be liable for any damage resulting from any infringement or other violation of any individual or entity’s copyright, trademarks or other proprietary rights and for any other harm or loss resulting from any content you post.
  2. you must not post any personal or security information about yourself, your Gather Account, or about anyone else or their Gather Account and you must not try to obtain the personal or security information of somebody else;
  3. you must not provide investment advice, portfolio management services, or any other type of service which requires you to be authorised by a regulator;
  4. you must not post that Gather endorse or warrant your content;
  5. you must not advertise or promote another business or service or any commercial content, including spam, without prior written consent in writing from Gather.
  6. you must not post anything abusive, inciteful, defamatory, harassing, insulting, sexually explicit, offensive, racist, rude, hateful, threatening, violent or illegal.

20. Contract Notes and Reports

21. Conflicts of Interest

22. Custody

23. Key Risks of Using Our Services and Exclusion of Liability

24. Force Majeure

25. Referrals

26. Revisions

  1. if we are required to do so to comply with the FCA Rules or any other Applicable Law or regulation;
  2. to reflect changes in the costs and expenses that we incur (or reasonably expect to incur) in providing the services to you, including to take account of changes in the rates of inflation, taxes or interest.
  3. to make these terms fairer to you or easier to understand, or to correct mistakes;
  4. to reflect changes in market practice or conditions;
  5. to enable us to make reasonable changes to the way we provide our services as a result of changes in the financial services sector, technology, or available products; and
  6. to reflect changes to our arrangements with Service Providers.

27. Termination

  1. your Gather Account has not held any securities or cash for a period exceeding 3 months
  2. there has been no activity on your Gather Portfolio for a period exceeding 18 months;
  3. you fail to make payment of any of the amounts owed to us under the Gather Agreement;
  4. you become insolvent or bankrupt or are subject to any insolvency proceedings/arrangements;
  5. you have materially breached any of the terms of the Gather Agreement or have otherwise provided us with false or misleading information, or you are in breach of any of these Terms and have not remedied this breach within three months of us having notified you of such breach;
  6. you do or fail to do any act which jeopardises the continuance of the Service(s);
  7. you breach any of the FCA Rules, FSMA or any other Applicable Law and this cannot be remedied; or
  8. where an Event of Default has occurred with respect to you or as set out at clause 29; or
  9. where you have failed to provide information and/or documentation which we are required to obtain from you to comply with our anti-money laundering obligations, whether initially or on an ongoing basis;

28. Agreement Not Transferable

  1. Any associated entity or subsidiary company of Gather; or
  2. To a third party outside of 28.2.a above where we reasonably consider that the transfer will not compromise your rights under the Gather Agreement and the services to be provided to you.


29. Invalidity of Provisions

30. Taxes

31. Marketing and Promotions

  1. You are creating multiple accounts, including self-invitation to participate in a Promotion.
  2. You are engaging in actions that harm Gather’s brand or reputation.

32. Referrals by Client

33. Representations

  1. you have full power and authority to enter into these Terms and to perform all your obligations hereunder and, in respect of the Services, to instruct us to execute or arrange any transaction in investments as set out herein;
  2. you have adequate resources to enter into and perform any such transaction which you decide to undertake;
  3. All information you have given, or shall give, to us is true and complete as of the date of these Terms and at the time of any transaction, and any changes to such information will be promptly notified to us.

34. Governing Law and Entire Agreement

35. Event of Default

36. Modification

Appendix 1





Financial Ombudsman Service, Exchange Tower, Harbour Exchange Square, London E14 9SR.

Telephone: 0800 023 4567 or 0300 123 9 123;

email: complaint.info@financial-ombudsman.org.uk ; and

website:  www.financial-ombudsman.org.uk

Appendix 2

Appendix 3

When ISAs are available, these ISA Terms apply to the Individual Savings Account that you have with GATHER and are supplementary to any terms you have with them.

If there is any conflict between these ISA Terms and any other Terms, the ISA Terms will apply.











Appendix 4




In essence, a conflict of interest is a situation in which Gather (or any of its personnel) finds itself in a position where its interests conflict with the duties and obligations owed to its clients or a situation in which Gather’s duty to one client conflicts with its duty to another. Identifying conflicts of interest for the purposes of identifying the types of conflict and potential conflicts that arise, which may entail a material risk of damage to the interests of a client, we must take into account whether Gather or its directors, employees or contractors (“Gather Personnel’’) or any other person linked by control to Gather:


We have identified a number of situations which may give rise to a potential conflict of interest. These situations include, but are not limited to, the following:


We seek to organise our business in such a way as to avoid conflicts of interest arising.

Appendix 5


Appendix 6

What is Copy Investing?

Regulatory status of the Copy Investing service and suitability assessment

Limitations to our Copy Investing service

Understanding the risk associated with Copy Investing