LEGAL · VULNERABLE CUSTOMER

Vulnerable customer policy

Holdwell's customers are, by definition, in a category the FCA classes as vulnerable. We treat that as the rule, not the exception.

Last updated · 19 May 2026

FCA context

The Financial Conduct Authority's FG21/1 guidance places people in recovery from problem gambling in the "vulnerable" customer category. Our entire customer base starts there. We design every default for that case.

What that means in design

Friction goes up front. Loosening any safety control needs a 24-hour cool-off and your sponsor circle's co-sign. There is no in-app override in the moment of urge.

Crisis is one tap. Anna detects crisis language. The right helpline is on the same screen. A clinical reviewer is paged inside the hour and the page is visible to you.

Disclosure is opt-in. Vulnerability flags on your record are visible to you. They are never exposed to sponsors. They never affect product pricing in a way you don't see.

Support routes

If you are in crisis right now: GamCare (UK gambling helpline, free, 24/7) on 0808 8020 133. Samaritans (self-harm, suicidality) on 116 123.

If you want to discuss a vulnerability concern with Holdwell directly, emailsafeguarding@holdwell.app. We aim to respond within one business day.

Third party

If a clinician, social worker, or family member needs to flag a concern on behalf of someone else, write to safeguarding@holdwell.app. We will respond with the consent and verification path we use under GDPR Article 6(1)(d) (vital interests).