Privacy statement
Privacy Policy
The Firm referred to in the Contact section of this Website is committed to protecting and respecting your privacy. This Privacy Policy will inform you as to how we look after your personal data when you visit our Website and tell you about your privacy rights and how the law protects you. Please read this Privacy Policy together with the embedded Cookie Policy with care before you use this Website. If you do not accept this Privacy Policy, please do not use this Website.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how we collect and process your personal data through your use of and interaction with the Website. This Website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
Controller
The Firm referred to in the Contact section of this Website is the controller (i.e. is responsible for the keeping and use of your personal information).
Contact details
If you have any questions about this Privacy Policy, please contact us here.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the Privacy Policy and your duty to inform us of changes
This version was last updated on 8th October 2026.
We will update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we will update the date at the top of this section and post it on our Website. If we make material changes to it or the ways we process personal information, we will notify you (by, for example, prominently posting a notice of the changes on our Website before they take effect or directly sending you a notification by email).
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data includes first name and last name.
- Contact Data includes email addresses and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
- Profile Data includes your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use the Website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We may also collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Where we have a need and lawful basis to do so, this data is recorded and used strictly in line with data protection law. Any information about criminal convictions and offences will only be collected where there is a lawful basis to do so.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with certain services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. The Website includes functions that allow you to give us your Identity and Contact Data by signing up to our newsletter, requesting a call back or corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Instruct or are interested in using our services;
- Subscribe to our blogs or publications;
- Request marketing information about our services to be sent to you;
- Enter a competition or promotion, or complete a survey; or
- Give us feedback on our services.
- Automated technologies or interactions. As you interact with the Website we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties: analytics providers such as Google, based outside the UK.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract for services we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you by email and the use of non-essential cookies and tracking technologies. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| PURPOSE/ACTIVITY | TYPE OF DATA | LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST |
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In each instance, the functionality has been included so that you will be unable to provide your personal details until you tick a box to confirm that you have read and agree to the Policy. All communications we send to you are tailored to the content you are interested in and you have the option to ‘unsubscribe’ if you no longer wish to receive any communications from us. |
To manage our relationship with you which will include:
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| To enable you to complete a survey |
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| To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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| To deliver relevant Website content to you and measure or understand the effectiveness of the content we serve to you |
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Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences |
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Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
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Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us by signing up to the newsletter on the Website, have purchased services from us, or provided us with your details when you completed a survey or registered for marketing and, in each case, you have opted in to receive that marketing.
Opting out
You can ask us to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you, or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.
Cookies
What are cookies? Cookies are small pieces of data that websites store on your browser when you visit them. They are useful because they allow us to recognise your visit and collect information about how you use our website.
You can choose which types of optional cookies you want to accept and can manage your settings at any time.
For more information about cookies visit www.allaboutcookies.org or www.youronlinechoices.eu.
Pixel Tracking
Some of our webpages and emails contain pixel tags (also referred to as web beacons, web bugs, tracking pixels, java tags and clear gifs). These allow us to:
- collect information on how you use our websites and interact with our emails (for example, the number of users who have visited a page, opened an email or followed links); and
- retarget users who have come from social media or email by personalising online services, marketing communications and ads.
Pixel tags may collect technical information such as your IP address and device details. Where we use them for analytics, marketing or retargeting, we only do so with your consent, which you can manage or withdraw at any time through our cookie settings.
Accept or block cookies
You can block or delete any cookies from any website by activating the setting on your browser. However, please note that if you block all cookies you might not be able to access all or part of our website.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
| PURPOSE/ACTIVITY | TYPE OF DATA | LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST |
| Personal information is stored within an online marketing platform. The core platform is hosted by StablePoint in the UK. |
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All personal data is kept within the platform and we have full control of the data within the platform. |
In addition to the above, we may share your personal data with:
- service providers acting as processors who provide IT, system administration, hosting and analytics services;
- professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
- HMRC, regulators and other authorities who require reporting of processing activities in certain circumstances; and
- third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Some of our external third parties (such as analytics providers) are based outside the UK, so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government; or
- where we use certain service providers, we may use specific contracts or approved transfer mechanisms which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
As a firm regulated by the Financial Conduct Authority (FCA), we are required to keep records of the advice and services we provide for minimum periods set by the FCA and other laws. These vary by type of record. For example:
- records of our advice, and of why a product was recommended as suitable for you, must usually be kept for at least three years;
- certain records relating to a mortgage must be kept for as long as the mortgage contract lasts;
- identity and anti-money laundering checks must be kept for five years after our business relationship with you ends; and
- other records must be kept for as long as is relevant to the purpose for which they were made.
In practice, we keep client records for six years after our relationship with you ends, or longer where the rules above require it. This allows us to deal with any complaint, regulatory enquiry or legal claim that may arise. Enquiries made through this Website that do not lead to us providing you with services are kept only for as long as is necessary to deal with your enquiry.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see “Request erasure” in section 9 below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
- Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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