Wealth portal

Privacy Policy

This privacy notice tells you what to expect us to do with your personal information.

Contact details

If you have any questions please contact Alex Bond, Technology Director, using the following channels:

Post: Seven Hills Business Centre, South Street, Morley, Leeds, West Yorkshire, LS27 8AT

Telephone: 01484 253067

Email: hello@cadencefp.co.uk

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

  • Names and contact details
  • Addresses
  • Gender
  • Occupation
  • Date of birth
  • Marital status
  • Third party information (such as family members or other relevant parties)
  • Payment details (including card or bank information for transfers and direct debits)
  • Financial data (including income and expenditure)
  • Transaction data (including details about payments to and from you and details of products and services you have purchased)
  • Usage data (including information about how you interact with and use our website, products and services)
  • Employment details (including salary, sick pay and length of service)
  • Credit history and credit reference information
  • Health information (such as medical records or health conditions)
  • Information relating to compliments or complaints
  • Video recordings
  • Audio recordings (e.g. calls)
  • Records of meetings and decisions
  • Account access information
  • Website user information
  • National Insurance number and taxpayer reference
  • Identification documents (such as passport or driving licence for identity verification)
  • Tax position and historical returns
  • Pension and retirement information

We also collect or use the following special category information to provide and improve products and services for clients. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following personal 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
  • Technical data, including information about browser and operating systems

We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:

  • Names and contact information
  • Client accounts and records
  • Call recordings
  • Financial information e.g. for fraud prevention or detection
  • Location data

We collect or use the following personal information for information updates or marketing purposes:

  • Names and contact details
  • Profile information
  • Marketing preferences

We collect or use the following personal information to comply with legal requirements:

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

We also collect or use the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following personal information to protect client welfare:

  • Names and contact information
  • Client account information
  • Health and wellbeing information
  • Emergency contact details

We also collect or use the following special category information to protect client welfare. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details
  • Addresses
  • Account information
  • Purchase or service history
  • Call recordings
  • Relevant information from previous investigations
  • Customer or client accounts and records
  • Financial transaction information

We also collect or use the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following personal information for website usage and analytics:

  • Technical data (such as your IP address, browser type and version, time zone setting, operating system and platform)
  • Usage data (information about how you use our website, including pages visited and browsing patterns)
  • Cookie data (see our Cookies Policy for details of the cookies we use and how to manage your preferences)

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. 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 in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

If you make a request, we must respond to you without undue delay and in any event within one month.

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

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using 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. Our legitimate interests are:
    • We have a legitimate interest in collecting and using personal information to operate, monitor and improve our financial advice services. This includes ensuring the quality and consistency of advice, maintaining accurate client records, carrying out internal compliance reviews, preventing fraud, managing business risk, training staff, and improving our systems and processes. Processing this information enables us to deliver appropriate and effective services to clients, meet professional standards, and maintain the security and integrity of our systems. It also supports the ongoing suitability of advice and helps us identify and address potential issues before they cause harm. We carefully balance these interests against individuals’ rights and freedoms. We only process information that is necessary for these purposes, retain it in line with regulatory requirements, apply appropriate technical and organisational security measures, and do not use the information in ways that would be unexpected or intrusive. Individuals retain the right to object to processing based on legitimate interests where applicable.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using 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. Our legitimate interests are:
    • We have a legitimate interest in collecting and using personal information to administer and operate client accounts effectively and securely. This includes maintaining accurate records, managing client portals and access controls, processing payments and fees, monitoring transactions for errors or irregularities, ensuring system security, and carrying out internal compliance and audit activities. Processing this information enables us to provide a reliable and efficient service, safeguard client assets and information, prevent fraud, and ensure continuity of service. It also supports our ability to maintain accurate records and respond appropriately to client requests and regulatory enquiries. We carefully balance these interests against individuals’ rights and freedoms. We only process information that is necessary for account administration, apply appropriate technical and organisational security measures, restrict access to authorised personnel, and retain information in accordance with regulatory requirements. This processing does not override individuals’ rights, and clients may object to processing based on legitimate interests where applicable.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using 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. Our legitimate interests are:
    • We have a legitimate interest in collecting and using personal information to prevent, detect and investigate financial crime, including fraud, money laundering, terrorist financing and other unlawful activity. This helps protect our clients, our organisation and the wider financial system from financial harm and abuse. Processing this information allows us to verify identities, monitor transactions for unusual or suspicious activity, investigate potential irregularities, and respond appropriately to concerns or suspected criminal conduct. These activities support the integrity and security of our services and help ensure that client assets and personal information are protected. We carefully balance these interests against individuals’ rights and freedoms. We only process information that is necessary and proportionate for crime prevention purposes, restrict access to authorised personnel, apply appropriate technical and organisational security measures, and retain information in accordance with legal and regulatory requirements. This processing does not override individuals’ rights, and individuals may object where applicable, except where processing is required by law.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legitimate interests – we’re collecting or using 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. Our legitimate interests are:
    • We have a legitimate interest in using personal information to provide relevant information about our services, updates about financial planning matters, and invitations to events or seminars that may be of interest to clients and prospective clients. This helps us maintain relationships, ensure individuals are aware of developments that may affect their financial planning, and inform them about services that could be beneficial to them. Where permitted by law, we may use limited information such as contact details and details of services previously provided to ensure that communications are relevant and proportionate. This allows us to avoid sending unnecessary or inappropriate information. We carefully balance our interests against individuals’ rights and expectations. Individuals can opt out of marketing communications at any time, and we maintain suppression lists to respect those preferences. We do not use sensitive personal information for marketing purposes, and we limit the information processed to what is necessary for these communications. We consider that the impact on individuals is minimal, as communications relate to financial services that are aligned with their existing relationship or expressed interests.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information to comply with legal requirements:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information to protect client welfare are:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using 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. Our legitimate interests are:
    • We have a legitimate interest in collecting and using personal information to identify and support clients who may be vulnerable or at risk of financial harm. This includes understanding factors such as health conditions, life events or personal circumstances that may affect a client’s ability to make informed financial decisions. Processing this information enables us to tailor our services appropriately, apply additional safeguards where necessary, prevent potential financial abuse or detriment, and ensure that advice remains suitable and aligned with a client’s needs and objectives. This supports good client outcomes and helps protect individuals from avoidable harm. We carefully balance these interests against individuals’ rights and freedoms. We only collect information that is necessary and proportionate for safeguarding and vulnerability purposes, restrict access to authorised personnel, apply appropriate technical and organisational security measures, and retain information only for as long as required. We do not use this information for unrelated purposes. Individuals retain the right to object to processing based on legitimate interests where applicable.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using 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. Our legitimate interests are:
    • We have a legitimate interest in collecting and using personal information to respond to queries, investigate complaints, and manage or defend legal claims. This enables us to assess concerns fairly, review the advice and services provided, maintain accurate records, and take appropriate remedial action where required. Processing this information supports transparency, accountability and good client outcomes. It allows us to cooperate with regulators, the Financial Ombudsman Service, professional indemnity insurers and legal advisers where necessary, and to ensure that disputes are resolved properly and in accordance with regulatory and legal standards. We carefully balance these interests against individuals’ rights and freedoms. We only use information that is relevant and necessary for investigating and resolving the matter, restrict access to authorised personnel, apply appropriate technical and organisational security measures, and retain information in line with regulatory retention requirements. This processing does not override individuals’ rights, and individuals may object to processing based on legitimate interests where applicable.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for website usage and analytics are:

  • Legitimate interests – we’re collecting or using your information because it benefits our organisation without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
    • We have a legitimate interest in understanding how visitors use our website so that we can improve its content, functionality and user experience. We collect anonymised or pseudonymised analytics data to identify popular content, monitor site performance and inform improvements. Where cookies or similar technologies are used, we obtain consent via our cookie consent tool before they are placed. We carefully balance these interests against individuals’ rights and freedoms. We minimise the data collected, do not use it to identify individual visitors, and retain it only for the period necessary for analytical purposes. Individuals can manage their cookie preferences at any time using the cookie settings on our website.

Where we get personal information from

  • Directly from you
  • Regulatory authorities
  • Legal bodies or professionals (such as courts or solicitors)
  • Publicly available sources
  • Credit reference agencies
  • Suppliers and service providers
  • Investment platforms and product providers

How long we keep information

We retain personal data for the minimum period necessary to meet our regulatory and legal obligations.

Where records relate to ongoing legal claims, regulatory investigations, or complaints that have not been fully resolved, we may retain personal data beyond the standard retention period until the matter is concluded.

Once the relevant retention period has expired, personal data is securely deleted or anonymised. Anonymised data may be retained for analytical purposes.

For more information on how long we store your personal information, please contact us using the details provided above.

Who we share information with

Data processors

Family Capital Limited

This data processor does the following activities for us: Principal Firm that provides the Customer relationship management (CRM) and back-office system and services.

Others we share personal information with

  • Insurance companies, brokers or other intermediaries
  • Professional or legal advisors
  • Regulatory authorities
  • External auditors
  • Organisations we’re legally obliged to share personal information with
  • Suppliers and service providers
  • Pension providers, investment platforms and other product providers

Sharing information outside the UK

Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

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 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

We’d love to hear from you.

Start the conversation, and let’s explore how we can help you.

    01484 253067
    hello@cadencefp.co.uk

    Cadence Financial Planning Limited is an appointed representative of Family Capital Limited, which is authorised and regulated by the Financial Conduct Authority. It is entered on the FCA register (https://register.fca.org.uk/) under company number 14496215.

    Company registered in England, number 14496215. Registered office: Seven Hills Business Centre, South Street, Morley, Leeds, England, LS27 8AT. The Financial Ombudsman Service is available to sort out individual complaints that clients and financial services businesses aren’t able to resolve themselves. To contact the Financial Ombudsman Service, please visit www.financial-ombudsman.org.uk.

    The guidance and/or advice contained within this website are subject to the UK regulatory regime, and are therefore targeted at consumers based in the UK. A copy of our Privacy policy can be found here. NB: the value of your investments can go down as well as up and you may not get back the amount you invested.

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