Privacy Policy

This privacy notice explains how we use any personal information we collect about you.

What information do we collect about you?

We collect information about you when you engage us for financial planning/financial advice/investment management services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data, such as data about your health, if necessary for providing our services.

We may also collect information when you voluntarily complete client surveys or provide feedback.

Information relating to the usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We will use the information collected from the website to personalise your repeat visits to the site.

Information about connected individuals

We may need to gather personal information about your close family members and dependents to effectively provide our service to you. In such cases, it will be your responsibility to ensure that you have the consent of the people concerned so that they can pass their information on to us. We will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.

Why do we need to collect and use your personal data?

We must have a lawful basis to process your personal data. Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

We have a contractual obligation

We intend to use this primary legal basis to process your data. The personal information we collect about you is essential to effectively carry out the services we have agreed to deliver to you.

We have a legal obligation

Collecting personal data is sometimes needed to meet our legal and regulatory obligations. For example, UK anti-money laundering legislation may require us to collect personal information to verify your identity.

We will obtain your consent

Special category data, such as health information, is often required to provide our services. We will obtain your explicit consent to collect and process this information when necessary.

From time to time, we may wish to contact you to offer additional products or services that may interest you. To do this, we will obtain your consent.
You may withdraw your consent anytime by notifying us at our main business address.

We have a legitimate interest

We rely on legitimate interest to retain relevant data to assess the appropriateness of our services, defend future complaints, and meet our Professional Indemnity Insurer’s expectations.

How will we use the information about you?

We collect information about you to provide you with the services for which you engage us.

Who might we share your information with?

If you agree, we may email you about other products or services that we think may interest you.

We won’t share your information for marketing purposes with companies outside our group of companies / other companies.

To effectively deliver our services to you, we may send your details to third parties, such as those we engage for professional compliance, accountancy, or legal services and product and platform providers that we use to arrange financial products for you.

Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing are clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.

Where your personal data needs to be forwarded to a third party, we’ll use appropriate security measures to protect it in transit. Methods used to enhance the security of the data during transfer, such as password protection and/or encryption etc., should be mentioned here.

To fulfil our obligations regarding preventing money laundering and other financial crimes, we may send your details to third party agencies for identity verification.

How long do we keep hold of your information?

We will retain the personal data necessary to provide services to you throughout our relationship and will take all reasonable steps to keep it up to date.

We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:

  • Five years for investment business
  • Three years for mortgage business
  • Indefinitely for pension transfers and opt-out business
  • Three years for insurance business

These are the minimum periods during which we have a legal obligation to retain your records.

We reserve the right to retain data longer where we believe it’s in our legitimate interests. Save for the minimum periods specified above, we’ll not keep your personal data for more than five years after our relationship ends.

You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests, as noted above.

How can I access the information you hold about me?

You have the right to request a copy of our information about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details noted below.

When your personal data is processed by automated means, you can ask us to transfer it to another organisation for their use.

We are obligated to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information you think is incorrect.


We would like to send you information about our products and services that may interest you. You may opt-out later if you agree to receive marketing information.

You have a right to stop us from marketing to you. Please email or post if you no longer wish to be contacted for marketing purposes.


We use cookies to track website visitor use and compile statistical reports on website activity.

For further information, visit

You can set your browser not to accept cookies, and the above website will tell you how to remove cookies from your browser. However, some of our website features may not function in a few cases.

Other websites

Our website contains links to other websites. This privacy policy only applies to this website, so you should read their privacy policies when you link to other websites.

What can you do if you are unhappy with how your personal data is processed?

You also have a right to complain to the supervisory authority for data protection. In the UK, this is:

Information Commissioner’s Office
Wycliffe House
Water Lane

Changes to our privacy policy

We keep our privacy policy under regular review and will place any updates on this web page when they occur. This privacy policy was last updated on 01/03/2024.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

  • By email at
  • Or write to us at Halleywell Limited, 8 Thorpe Road, Norwich, NR1 1RY