Website Privacy Policy
Effective Date: 01/09/2026
Introduction
This Privacy Policy explains how our firm, collects, uses, stores, and protects your personal data in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018.
If you have any questions about this policy or our data practices, please contact us using the details below:
Contact Name: Angela Morton
Address: 76 Highgate Road Bradford BD13 1ES
Telephone: 01274 889943
Email: angela@project-financial.co.uk
Website: www.project-financial.co.uk
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1. What Data We Collect and How We Use It
1.1 Types of Data Collected
To provide financial advisory services, including insurance and mortgage provision, we may collect the following personal data:
- Identity and Contact Data: Name, address, email, telephone number, date of birth.
- Financial Data: Details of your financial circumstances, objectives, income, assets, and liabilities.
- Special Category Data: Health information or other sensitive data (e.g., racial or ethnic origins, biometric data) necessary for insurance underwriting or other financial services.
- Website Usage Data: IP addresses, browser type, and cookies (see Section 6 for details).
- Enquiry Data: Information provided through our website’s enquiry form or other contact methods.
1.2 How We Use Your Data
We use your data to:
- Provide financial advisory services, including assessing your demands and needs (ICOBS 5.2).
- Arrange insurance or mortgage products on your behalf.
- Respond to enquiries and communicate with you.
- Comply with legal and regulatory obligations, including FCA and ICO requirements.
- Maintain records for defending potential legal claims or resolving disputes.
- Improve our website and services through analytics (where applicable).
1.3 Lawful Basis for Processing
We process your personal data based on the following lawful bases under UK GDPR:
- Contractual Necessity (Article 6(1)(b)): To provide services, respond to enquiries, or perform a contract with you.
- Legitimate Interests (Article 6(1)(f)): For internal record-keeping, improving our services, or contacting you about relevant services (unless overridden by your interests or rights).
- Legal Obligation (Article 6(1)(c)): To comply with FCA, ICO, or other regulatory requirements.
- Consent (Article 6(1)(a)): For processing special category data (e.g., health information for insurance underwriting) or direct marketing (where applicable).
For special category data, we will only process such data with your explicit consent (UK GDPR Article 9(2)(a)) or where necessary for the establishment, exercise, or defence of legal claims (Article 9(2)(f)).
1.4 Your Choice
Providing personal data is voluntary. However, if you choose not to provide certain data, we may be unable to assist you with your financial or insurance needs or respond to your enquiry.
2. Special Category Data
2.1 Definition
Special category data includes:
- Racial or ethnic origins
- Political opinions
- Religious or philosophical beliefs
- Trade union membership
- Genetic or biometric data
- Health data
- Data concerning sex life or sexual orientation
2.2 Processing Special Category Data
We may need to process special category data (e.g., health information) for insurance underwriting or other financial services. We will:
- Obtain your consent before collecting or processing such data,.
- Discuss with you the necessity of providing such data and explain its purpose.
- Minimise the collection and use of special category data to what is strictly necessary.
3. Sharing Your Data
3.1 Data Controllers
We may share your data with the following data controllers, who are responsible for their own data processing:
- Product and Service Providers: Insurers, mortgage lenders, or other providers relevant to your financial services.
- Compliance and Regulatory Bodies: The FCA, Financial Ombudsman Service (FOS), or other regulators where required by law.
- Compliance Monitoring Services: Organisations that support our regulatory compliance.
All data controllers we share data with must be registered with the ICO or an equivalent supervisory authority in a jurisdiction deemed adequate by the UK ICO.
3.2 Data Processors
We use external data processors to support our operations, including:
- Secure File Sharing: For sharing documents securely.
- Data Backup: To ensure data security and integrity.
- Telephony Services: For client communications.
- Regulatory Compliance: For reporting and compliance purposes.
- Research and Report Writing: For preparing financial advice or reports.
Below is a list of our current data processors and the types of data they process:
| Processor | Type of Processing & Data |
|---|---|
| Intelligent Office | Secure file sharing: Name, contact details, financial data |
| Intelligent Office | Data backup: All personal data collected |
| Telephony: Contact details, call recordings | |
| Cogio Ltd. | Website operation and technical support: Contact form submissions including name, contact details and message content |
| Cogio Ltd | Newsletter: Name, e-mail address |
| Mailchimp | Newsletter: Name, e-mail address |
| Microsoft | |
| Microsoft (Teams) | Video calling |
All processors are contractually obliged to process data only on our instructions, in compliance with UK GDPR and the Data Protection Act 2018, and maintain appropriate security measures.
3.3 Minimising Data Sharing
We seek to minimise the personal data shared and, where possible, anonymise data. However, identifiable data may be necessary to provide services or comply with regulatory requirements.
3.4 No Unauthorised Sharing
We will not share your data with third parties for purposes other than those outlined above without your express consent, except where required by law or in the event of a business transfer (e.g., sale or merger).
4. Marketing
4.1 Use of Data for Marketing
We will only use your data for marketing purposes (e.g., informing you about our services) where we have your explicit consent or a legitimate interest (e.g., contacting existing clients about relevant services, provided it complies with ICO guidance and the Privacy and Electronic Communications Regulations (PECR)).
4.2 No Third-Party Marketing
We will never share your data with third parties for their marketing purposes.
4.3 Opting Out
You can opt out of marketing communications at any time by contacting us or using the unsubscribe option in our communications.
5. Data Retention
5.1 Retention Period
We will retain your personal data for the duration of our business relationship and as required by law or regulation thereafter, including:
- FCA Requirements: Records related to insurance or financial advice must be retained for at least 3 years (ICOBS 2.5), with some records (e.g., pension-related) retained indefinitely.
- Legal Defence: We may retain data beyond regulatory periods to defend potential legal claims (e.g., under the Limitation Act 1980).
5.2 Archiving
Where we no longer need regular access to your data, it will be securely archived to minimise processing, in line with UK GDPR’s data minimisation principle (Article 5(1)(c)).
6. Where We Store Your Data
6.1 Storage Location
All personal data is stored on secure servers located in the UK or a satisfactory jurisdiction under terms compatible with UK law, and backed up on cloud-based servers in the UK or a satisfactory jurisdiction under terms compatible with UK law.
6.2 Security Measures
We use industry-standard security measures, including Secure Socket Layer (SSL) encryption for website forms, to protect your data.
6.3 International Transfers
If data is transferred outside the UK, we ensure the recipient is in a jurisdiction deemed adequate by the ICO or is subject to appropriate safeguards (e.g., Standard Contractual Clauses) under UK GDPR Article 46.
7. IP Addresses and Cookies
7.1 Cookies
Our website uses cookies to enhance your experience. A cookie is a small file stored on your device that records how you interact with our website. We use the following types of cookies:
- Vital Cookies: Essential for website functionality (e.g., remembering text entered during a session).
- Performance Cookies: Collect anonymised data to improve website performance (e.g., Google Analytics for usage statistics).
- Functionality Cookies: Remember user preferences (e.g., language or region) for a personalised experience.
We do not use advertising cookies or track your activity across other websites.
7.2 Cookie Consent
We obtain your consent for non-essential cookies in line with PECR and ICO guidance. You can manage cookie preferences via our website’s cookie banner.
7.3 IP Addresses
We may collect IP addresses to analyse website usage or detect security issues. This data is anonymised where possible and processed under our legitimate interests.
8. Your Rights
Under UK GDPR, you have the following rights regarding your personal data:
- Right to be Informed (Articles 13-14): To know what data we collect, how it is used, and with whom it is shared.
- Right of Access (Article 15): To request a copy of your personal data.
- Right to Rectification (Article 16): To correct inaccurate or incomplete data.
- Right to Erasure (Article 17): To request deletion of your data (subject to legal or regulatory obligations).
- Right to Restrict Processing (Article 18): To limit how we process your data.
- Right to Data Portability (Article 20): To receive your data in a structured, machine-readable format.
- Right to Object (Article 21): To object to processing based on legitimate interests (e.g., marketing).
- Rights Related to Automated Decision-Making (Article 22): To challenge decisions made solely by automated means (we do not currently use such processes).
To exercise these rights, please contact us using the details in Section 11. We will respond within one month, as required by UK GDPR, unless the request is complex.
9. Complaints
If you are dissatisfied with how we handle your personal data, please contact us first to resolve the issue. You may also lodge a complaint with the UK Information Commissioner’s Office (ICO):
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk
For complaints about our financial services, you may contact the Financial Ombudsman Service (FOS):
Address: Exchange Tower, London E14 9SR
Telephone: 0800 023 4567
Website: www.financial-ombudsman.org.uk
10. Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. Updates will be posted on our website, and, where appropriate, we will notify you by email or post. Please check our website regularly for the latest version.
11. Contact
For any questions or to exercise your data protection rights, please contact:
Contact Name: Angela Morton
Address: 76 Highgate Road Bradford BD13 1ES
Telephone: 01274 889943
Email: angela@project-financial.co.uk
Website: www.project-financial.co.uk