CLICK HERE to download a PDF version of our Privacy Notice.

Why You Should Read This Document

During our work together, we may request detailed personal information about your circumstances, finances, and in some cases, your health or family health history (“Your Personal Data”).
This notice explains how we use your information and outlines the rights you have regarding it.

What We Mean by “Your Personal Data”

Your Personal Data includes any information that identifies you directly or indirectly.

Direct identifiers include:

• Name

• Address

• Date of birth

• National Insurance number

Indirect identifiers include:

• Employment status

• Financial information

• Health history

• Any details linked to your cultural or social identity

When advising on investments or insurance, your data may include:

• Title, name, date of birth, gender, nationality, marital status, contact details, identity documents

• Employment details, income, bonuses, benefits, employment history

• Bank details, tax information, loans, credit history, income and expenditure, family circumstances

• Health status, medical reports, treatment history

• Existing investment or insurance policies and their terms

The Basis on Which We Use Your Personal Data

We use Your Personal Data for the following purposes:

Contractual necessity

When discussing or arranging investments or insurance, both parties enter into a contract for services. We use your data to fulfil this contract.

Legitimate business interests

We may use Your Personal Data:

• During initial discussions

• After a contract ends

• To respond to product provider or compliance queries

• To request feedback on our services

Legal and regulatory obligations

We may process Your Personal Data to meet obligations set by:

• The Financial Conduct Authority

• Other legal or regulatory bodies

Processing Special Category Data

When advising on certain insurance products such as life insurance or policies that support you in the event of accident or illness, we may need to process Special Data which includes:

• Ethnic origin

• Health and medical history

If you have children under 13, we may also process their information and Special Data.

Criminal disclosures

Some insurance arrangements require information about past or current criminal convictions or offences.

Use of Special Data

We process Special Data and Criminal Disclosures in the same way as Your Personal Data, strictly for:

• Making enquiries to insurers

• Assessing product suitability

Insurance intermediaries and insurers must be able to exchange such information to provide appropriate insurance solutions.

How We Collect Your Personal Data

We gather information from multiple sources, primarily directly from you:

You provide information:

• During meetings or calls

• In writing or by email

• When outlining your circumstances, needs, and preferences

We may also obtain data from third parties:

• Credit reference checks

• Your employer

• Publicly available sources such as the electoral roll

Where technology assists in verifying information such as credit status tools, we will only use it with your consent except for electronic ID checks. For these checks, your consent is not required but you will be informed of how the system works and its purpose.

How Your Personal Data Is Handled

We will:

Store and secure your data

In paper files, mobile devices, computer systems, email, and cloud storage. Access is restricted to employees and consultants where necessary.

Share data with product providers

We submit your Personal Data to investment or insurance providers in paper or secure digital formats to process enquiries and applications.

Use your data for service-related matters

Such as answering your queries or advising you of updates linked to your policies or products.

Sharing Your Personal Data

Your information may be shared with:

Third parties essential to delivering our services, including:

• Investment providers

• Insurance companies

• Compliance advisers

• Product specialists

Sharing occurs only to progress your enquiry or fulfil service obligations.
These parties cannot use your data for marketing purposes.

We do not expect to transfer your data outside the European Economic Area.

Security and Data Retention

We take reasonable steps to keep Your Personal Data secure and protected from unlawful access.

Your responsibilities include:

• Avoid sending confidential information through unprotected email

• Password protect attachments

• Use secure postage when sending original documents

Retention period

We keep your data for at least 6 years after the service or advice provided.
It may be held longer if required by regulatory bodies.

Your Rights Regarding Your Personal Data

You may request to:

• Obtain copies of Your Personal Data

• Ask for correction, deletion, or restriction of processing

• Have your data transferred electronically to another organisation

• Withdraw or change your marketing consent at any time

Details of how your request can be fulfilled will be provided upon contacting us.

How to Contact Us

If you have questions, need to exercise any rights, or wish to raise concerns about data use, contact:

Engage Wealth Management
First Floor
26 Stroudley Road
Brighton
BN1 4BH

If we believe we are legally permitted to refuse or alter your request, we will inform you.

Please notify us immediately if you become aware of unauthorised disclosure of Your Personal Data.

How to File a Complaint

If you are unhappy with how we have handled Your Personal Data, you may contact:

Information Commissioner’s Office (ICO)
Website: https://ico.org.uk/global/contact-us/
Address: Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF