Customer Privacy Notice

1. Contact details

2. What information we collect, use, and why

To provide and improve products and services for clients

• Names and contact details
• Addresses
• Occupation
• Payment details (including card or bank information for transfers and direct debits)
• Usage data (including information about how you interact with and use our website, products and services)
• Video recordings
• Audio recordings (e.g. calls)
• Records of meetings and decisions
• Website user information

For the operation of client or customer accounts

• Names and contact details
• Addresses
• Purchase or service history
• Account information, including registration details
• Information used for security purposes
• Marketing preferences

For information updates or marketing purposes

• Names and contact details
• Marketing preferences
• Website and app user journey information

To comply with legal requirements

• Name
• Contact information
• Client account information
• Any other personal information required to comply with legal obligations

To protect client welfare

• Names and contact information
• Client account information

For dealing with queries, complaints or claims

• Names and contact details
• Addresses
• Payment details
• Account information
• Purchase or service history
• Call recordings
• Customer or client accounts and records
• Financial transaction information
• Correspondence

3. Lawful bases and data protection rights

Under UK data protection law, we must have a "lawful basis" for collecting and using your personal information. You can find out more about lawful bases on the ICO's website.

Which lawful basis we rely on may affect your data protection rights, which are set out briefly below. You can find out more about your rights and the exemptions that may apply on the ICO's website.

If you make a request, we must respond without undue delay and in any event within one month. To make a data protection rights request, please contact us using the details in section 1 above.

Our lawful bases

For all categories of personal information listed in section 2, our lawful basis is legitimate interests: we collect or use your information because it benefits you, our organisation, or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

For more information on our use of legitimate interests, please contact us using the details in section 1.

4. Where we get personal information from

• Directly from you
• Market research organisations
• Providers of marketing lists and other personal information

5. How long we keep information

For full details on how long we retain personal information, please see our retention schedule.

6. Who we share information with

• Organisations we are legally obliged to share personal information with

7. How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details in section 1.

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