01 Who We Are
The data controller responsible for your personal data is TFAS Wealth Limited, trading as Financiable. We are a company registered in England and Wales (Company Number: 13664696) with our registered office at Second Floor, St Andrew's House, 119-121 The Headrow, Leeds, LS1 5JW.
We are registered with the Information Commissioner's Office (ICO) under registration number ZB370703.
We are also authorised and regulated by the Financial Conduct Authority (FCA reference: 968148).
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:
- By telephone: 0800 599 9692 (free)
- By post: Data Protection, Financiable, Second Floor, St Andrew's House, 119-121 The Headrow, Leeds, LS1 5JW
02 Personal Data We Collect
Depending on how you interact with our service, we may collect the following categories of personal data:
Information you provide directly:
- Full name;
- UK postcode and/or full address;
- Telephone number (mobile or landline);
- Email address (if provided);
- Details of the financial service you are seeking (e.g. pensions, investments, mortgages);
- Any other information you voluntarily provide in communications with us.
Technical and usage data collected automatically:
- IP address;
- Browser type and version;
- Operating system;
- Referring website URL;
- Pages visited on our website and time spent on each page;
- Date and time of your visit;
- Cookie data (see Section 9).
We do not intentionally collect any special category data (such as information about health, ethnicity, religion or political opinions). Please do not send us sensitive personal information.
03 How We Collect Your Data
We collect personal data through the following means:
- Enquiry form submissions: when you complete and submit the postcode/contact form on our website;
- Telephone calls: when you call us on 0800 599 9692, calls may be recorded for training and compliance purposes;
- Website analytics: through cookies and tracking technologies when you browse our website;
- Third-party lead sources: in some cases we may receive your details from trusted third-party marketing partners, where you have given consent for your data to be shared with financial services providers;
- Correspondence: when you contact us by post, email or any other means.
04 Why We Use Your Personal Data
We use your personal data for the following purposes:
- To provide our introduction service: to process your enquiry, identify suitable FCA-regulated financial advisors in your area, and pass your contact details to matched advisors so they can contact you;
- To communicate with you: to respond to your enquiries, provide information about our service, or to follow up on the status of your introduction;
- To comply with legal and regulatory obligations: including record-keeping requirements under FCA regulations and the Data Protection Act 2018;
- To improve our service: to analyse how our website and introduction process are used so that we can improve the user experience;
- To prevent fraud and misuse: to detect and prevent fraudulent or abusive use of our service;
- For direct marketing: only where you have given your consent, to send you information about financial services that may be of interest to you (see Section 11).
05 Legal Bases for Processing
Under the UK GDPR, we must have a lawful basis for processing your personal data. The legal bases we rely on are:
- Legitimate interests (Article 6(1)(f)): to operate and improve our introduction service, prevent fraud, and ensure the service functions correctly. We have carried out a legitimate interests assessment and are satisfied that our interests are not overridden by your rights;
- Performance of a contract / pre-contractual steps (Article 6(1)(b)): to process your enquiry and provide the introduction service you have requested;
- Legal obligation (Article 6(1)(c)): to comply with our obligations under FCA regulations, tax law and other applicable legislation;
- Consent (Article 6(1)(a)): where we process your data for direct marketing purposes, we will only do so with your explicit prior consent. You can withdraw your consent at any time (see Section 11).
06 Sharing Your Personal Data
We will share your personal data with:
- Financial advisors on our panel: we will share your name, postcode, telephone number and stated service requirement with one or more matched FCA-regulated financial advisors for the sole purpose of enabling them to contact you. These advisors are independently responsible for their own processing of your data in accordance with their own privacy policies and FCA obligations;
- Service providers: we use carefully selected third-party service providers to support our operations (e.g. cloud hosting, CRM software, analytics, telephony). These providers act as data processors under our instruction and are bound by contractual data protection obligations;
- Regulatory and law enforcement authorities: where required or permitted by law, we may disclose your data to the FCA, HMRC, ICO, police or other authorities;
- Business transfers: in the event of a merger, acquisition or sale of all or part of our business, your personal data may be transferred to the acquiring entity, subject to the same data protection commitments.
We will never sell your personal data to third parties for their own marketing purposes. We do not share your data with any person or organisation outside of those described above.
07 International Data Transfers
We are a UK-based business and store your personal data on servers located within the United Kingdom and/or the European Economic Area (EEA). We do not routinely transfer your personal data outside of the UK or EEA.
Where any of our service providers process data outside the UK or EEA, we ensure that appropriate safeguards are in place in accordance with UK GDPR requirements, such as the use of International Data Transfer Agreements (IDTAs) or standard contractual clauses approved by the UK Information Commissioner.
08 Data Retention
We retain your personal data only for as long as is necessary for the purposes for which it was collected, taking into account legal, regulatory and business requirements:
- Enquiry data (name, contact details, postcode, service type): retained for up to 3 years from the date of your enquiry, unless you request earlier deletion. This allows us to evidence compliance with FCA requirements and to respond to any queries or disputes;
- Telephone call recordings: retained for up to 12 months for training, quality assurance and compliance purposes;
- Website analytics data: aggregated and anonymised after 26 months;
- Financial and accounting records: retained for 6 years in accordance with HMRC requirements;
- Consent records (for marketing): retained for the duration of the consent period, plus 3 years after consent is withdrawn, to evidence that we had consent at the time of any marketing communications.
Once the applicable retention period has expired, we will securely delete or anonymise your personal data.
09 Cookies & Tracking Technologies
Our website uses cookies and similar tracking technologies to improve your experience and to help us understand how our website is used.
Types of cookies we use:
- Strictly necessary cookies: essential for the website to function correctly. These cannot be disabled;
- Analytics cookies: help us understand how visitors interact with our website (e.g. pages visited, time spent). We use anonymised data for this purpose. We may use services such as Google Analytics for this purpose;
- Marketing and tracking cookies: used to track conversions and the effectiveness of our advertising campaigns. These are only placed with your consent.
When you first visit our website, you will be asked to consent to non-essential cookies. You can change your cookie preferences at any time by adjusting your browser settings. Please note that disabling certain cookies may affect the functionality of our website.
For more information about cookies generally, visit allaboutcookies.org.
10 Your Rights Under UK GDPR
Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, you have the following rights in relation to your personal data:
| Right | What it means |
|---|---|
| Right of access | You can request a copy of the personal data we hold about you (a "subject access request"). |
| Right to rectification | You can ask us to correct inaccurate or incomplete personal data we hold about you. |
| Right to erasure | You can request that we delete your personal data where there is no compelling reason for us to continue processing it ("the right to be forgotten"). |
| Right to restrict processing | You can ask us to restrict how we use your data in certain circumstances, for example while a dispute is being resolved. |
| Right to data portability | You can ask us to provide your personal data in a structured, machine-readable format so that you can transfer it to another organisation. |
| Right to object | You have the right to object to our processing of your data where we rely on legitimate interests as our legal basis. You can also object to direct marketing at any time. |
| Rights related to automated decisions | You have the right not to be subject to a decision made solely by automated means, including profiling, where that decision has a legal or similarly significant effect on you. |
| Right to withdraw consent | Where we rely on your consent to process your data, you can withdraw that consent at any time without affecting the lawfulness of processing before withdrawal. |
To exercise any of these rights, please contact us in writing at the address set out in Section 1, or call us on 0800 599 9692. We will respond to your request within one calendar month of receiving it. We will not charge a fee for reasonable requests.
We may need to verify your identity before processing your request. In some circumstances we may be unable to fully comply with a request (for example, where compliance would conflict with a legal obligation), in which case we will explain our reasons.
11 Marketing Communications
We will only send you direct marketing communications (e.g. emails or text messages about financial services) where you have given your explicit consent to receive them.
You can opt out of marketing communications at any time by:
- Clicking the "unsubscribe" link in any marketing email;
- Texting STOP in response to any marketing text message;
- Calling us on 0800 599 9692;
- Writing to us at the address in Section 1.
Please note that opting out of marketing will not affect service-related communications (for example, information related to an ongoing enquiry). We will act on opt-out requests promptly and within no more than 10 business days.
We do not sell or share your contact details with third parties for the purpose of third-party direct marketing.
12 Data Security
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, disclosure, alteration, loss or destruction.
Our security measures include, but are not limited to:
- SSL/TLS encryption for all data transmitted through our website;
- Password-protected and access-controlled systems;
- Regular security reviews and software updates;
- Staff training on data protection and information security;
- Contractual data protection obligations for all third-party processors.
Whilst we take every reasonable precaution, no internet transmission or electronic storage is 100% secure. If you believe your interaction with us is no longer secure, please notify us immediately.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours as required by law and will notify you directly where the risk is assessed as high.
13 Children's Privacy
Our website and service are intended for adults aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If you are under 18, please do not submit any personal information through our website.
If we become aware that we have inadvertently collected personal data from a person under 18, we will take steps to delete that data as soon as possible. If you believe we have collected data from a minor, please contact us immediately.
14 ICO Registration & Raising a Concern
TFAS Wealth Limited is registered with the Information Commissioner's Office (ICO) under registration number ZB370703. You can verify this at ico.org.uk.
If you have a concern about how we have handled your personal data, we encourage you to contact us first so that we can try to resolve the matter:
- By telephone: 0800 599 9692
- By post: Data Protection, Financiable, Second Floor, St Andrew's House, 119-121 The Headrow, Leeds, LS1 5JW
If you are not satisfied with our response, or if you believe we are processing your data unlawfully, you have the right to lodge a complaint with the Information Commissioner's Office:
- Website: ico.org.uk/make-a-complaint
- Helpline: 0303 123 1113
- Post: ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
15 Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or for other operational reasons. The date at the top of this page indicates when the policy was last revised.
We will notify you of significant changes to this policy by posting a prominent notice on our website. Where required by law, we will seek your consent before applying any material changes to how we process your personal data.
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of our service after any changes indicates your acceptance of the revised policy.
This Privacy Policy was last updated on 1 January 2025.