1. Introduction

1.1 This website is owned and operated by Spence Financial Ltd (hereafter “we”, “our”or “us”).

1.2 During the financial planning process, we will ask you personal information, and in some cases, family details, which will be necessary for us to be able to advise you appropriately. This is known as Your Personal Data or Personal Information. We keep this within a “client file” in our secure electronic filing system and there are no paper copies retained.

1.3 We assume that where we are advising a couple (married or living as partners) that you are consenting for the information either of you provides and any future valuations to be shared with both parties unless and until you tell us otherwise (in writing).

2. Your Personal Data and the types of Personal Information we collect.

2.1 Your Personal Data or Personal Information means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example, your name, address, date of birth, National Insurance Number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, contact details or any other information that could be associated with your identity.

2.2 The types of Personal Information we collect may include, title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity. This is also likely to include employment and remuneration information, employment history, bank account details, tax information, loan and credit commitments, personal credit history, sources of income and expenditure, details of dependents, health status and history, details of treatments and prognosis, medical reports, pre-existing investments, mortgages, pensions and insurance products.

3. How we get the personal information and why we have it.

3.1 When you originally engage us to provide you with financial advice, at our initial meeting and during the analysis stage, we complete a structured fact-find with you to enable you to give us the information we need to advise you appropriately. Much of the information detailed in (2.2) will be collected and this information relates to your personal and financial circumstances, your objectives and goals, your attitude to risk and any existing financial products you hold as well as your health. It also includes, where it results in better planning or advice, personal information about your spouse and children. The information will enable us to ensure any financial advice given is entirely suitable and aligned to your financial objectives, investment risk profile and capacity for loss.

4. Will we share Your Personal Data?

4.1 Yes, with companies we use to deliver our services to you, for example, product and platform providers and our professional advisers.

4.2 And in order to fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies to check your identity.

4.3 Where we do share your information we will have a contract in place to ensure that the nature and purpose of their processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions. 

4.4 There may be times when we are required to use personal information for contractual responsibilities we may owe our regulator, The Financial Contact Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing your personal information to meet legal, compliance or other regulatory obligation to which we are subject.

4.5 The sharing of Your Personal Data does not entitle third parties to send you marketing or promotional messages. It is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in the Privacy Notice.

5. Retaining and security of Your Personal Data.

5.1 We will keep Your Personal Data in accordance with our legal responsibilities and will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

5.2 During the course of our relationship with you we will keep the personal data necessary to provide our services to you. We will take all reasonable steps to keep your personal data up-to-date.

6. How you can access the information we hold about you.

6.1 You can request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information please email or write to us.

6.2 You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

6.3 You have the right to ask us to rectify Personal Information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

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

6.5 You have the the right to object to the processing of your Personal Information in certain circumstances.

6.6 You have the right to ask that we transfer the Personal Information you gave us to another organisation, or to you, in certain circumstances.

6.7 You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at matthew@spencefinancial.co.uk or Loft 6, Ocean House, Clarence Road, Cardiff, CF10 5FR.

7. How to complain.

7.1 If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

8. Website.

8.1 We use cookies to collect information about how our website is used.  These are small text files placed on your computer to review how clients use our website so we can continually improve it.  You can set your browser not to accept these cookies if you choose. The most effective way to disable these is through your browser. We suggest consulting the help section of your browser, or taking a look at the “About Cookies” website.

9. Keeping the policy up to date.

9.1 We keep our privacy policy under regular review and we will inform you of any changes when they occur.  This privacy policy was last updated on 5 September 2022.