Privacy policy

Introduction

We need to collect and use some of your personal information so we can give you financial advice and manage the services you receive from us. We follow the UK GDPR and the Data (Consent and Use) Act 2025, which set out how we must protect your data and what your rights are.

Why We Need Your Information

We use your information so that we can:

• Provide financial planning and advice tailored to your needs
• Meet rules set by the Financial Conduct Authority (FCA), including keeping proper records
• Respond to legal or regulatory requests, such as preventing fraud or financial crime
• Run our business properly — for example, checking your products remain suitable, meeting anti‑money‑laundering obligations and dealing with complaints

Your Data and Your Rights

When we collect your information, we will always be able to tell you:

• Who the data controller is (this may be us or a third‑party provider)
• How to contact our Data Protection Officer
• Why we are using your information and the legal basis for doing so
• Who we may share your data with
• How long we will keep your data

Your rights include:

• Seeing the information we hold about you
• Asking us to correct inaccurate information
• Asking us to stop using your information (in certain circumstances)
• Asking us to delete your information
• Objecting to direct marketing
• Objecting to decisions made by computers
• Asking for a copy of your information in a portable format

We will normally respond to your requests within 30 days. There will be no charge to you for this, unless the request is totally unfounded or excessive – then we may charge a fee.

Sensitive Information

Sometimes we need more sensitive information — for example, details about your health if we are advising on pensions, protection or annuity products. We only collect this information when absolutely necessary and handle it with extra care.

Sharing Your Information

To provide our services, we may share your data with trusted third‑party companies such as compliance specialists, IT security providers and auditing firms. All companies we share data with operate in the UK unless we tell you otherwise.

How Long We Keep Your Information

We keep information only for as long as we need to. This includes:

• Agreements with you: 6 years after the agreement ends
• Investment records: while you are a client and at least 6 years afterwards
• FCA‑required records: normally 6 years, but indefinitely for certain pension‑related business
• HMRC‑related data: 7 years or longer if they consider a period “open”
• Legal proceedings: 6 years after proceedings end
• In general, no personal data is kept for more than 50 years

AI Tools

We may use technology solutions, including AI tools, to help us deliver our services efficiently and maintain accurate records. In doing so, your data may be stored or processed by us or by trusted third‑party providers, and in some cases may be held in different locations, including outside the UK.

We take appropriate steps to ensure your information is kept secure and handled in line with applicable data protection laws. Your rights in relation to your personal data apply equally to any information processed using these systems.

Marketing

We will only contact you about other financial products or services if you have given us your clear permission. You can change your preferences or withdraw consent at any time.

Post       o                         Email     o                         Telephone           o

If you do not tick any of the above options, we will assume that you do not wish to be contacted by us about other investment, pension or financial products and services.

Your Contact Options

Please contact Rob Starling, our Data Protection Officer, at our company address, or by telephone or email, if you wish to:

• Access your data
• Correct or delete data
• Change your marketing preferences
• Ask questions about how your data is used

You also have the right to complain in regard to any aspect of the processing of your data and any breach of the above rights to the relevant supervisory authority, who in the case of the UK is the Information Commissioners Office, whom may be contacted at:

• Online: ico.org.uk
• Phone: 0303 123 1113