Privacy Policy

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In the ordinary course of business, we collect, retain and use information about our clients’ financial situation in order to service them to high professional standards.

This information is collected from several sources, and may include information received from our clients:

• whether in writing;
• in person;
• by telephone;
• electronically; or
• on applications or other forms.

This information may include information about their transactions with our affiliates, and others which may consist of:

• information about account balances;
• counterparties to transactions;
• information we might receive from credit reporting companies such as credit reports; and
• information collected from the Internet

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We do not sell any information about our clients. We will disclose information about our clients to selected firms in the course of carrying on our business, i.e. to facilitate client introductions to third party firms. From time to time and when we deem it necessary to facilitate the handling of our relationship with our clients, we will share appropriate information with third parties and partner companies as permitted by law. We only share information that is required for third parties to perform their job. For example, we may disclose information to third parties such as data processing providers and product providers; to UK government entities in response to the obligatory provision of information, and as otherwise requested by our clients.

We maintain physical, electronic, and procedural safeguards to protect our clients’ personal information. We have strict internal policies against unauthorised use or disclosure of client information. Our clients’ information is accessible only to employees who need it to conduct our clients’ financial affairs or provide services to them. Our employees, and our account management practices, are governed by extensive regulatory procedures, and by internal procedures. Our staff members are reminded on a regular basis of their obligations with regard to the confidentiality of client information through employee training and by operating procedures.

• 6 years

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal data.

Your right to rectification – You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal data in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal data in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.

Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent.

You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

14th September 2026