Privacy Policy

Introduction

freshen-glow Limited ("we", "us", or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, store, and protect information about you when you use our website or engage our retirement planning services.

We take our responsibilities under data protection legislation seriously and are committed to transparency about how we handle your personal data.

Information We Collect

When you interact with our services, we may collect several types of information:

Information You Provide Directly

When you contact us or use our services, you may provide us with personal details including your name, email address, postal address, date of birth, employment details, and financial information relating to your pension arrangements. This information is necessary for us to provide retirement planning advice tailored to your circumstances.

Information Collected Automatically

When you visit our website, we automatically collect certain technical information including your IP address, browser type, operating system, pages viewed, time spent on pages, and referring website addresses. This information helps us understand how visitors use our website and improve the user experience.

Financial Information

To provide retirement planning services, we need to collect detailed financial information including details of your existing pension arrangements, income, assets, liabilities, and other relevant financial circumstances. We only collect this information when you engage our services and have consented to our processing of this sensitive data.

How We Use Your Information

We use the information we collect for specific, legitimate purposes:

Providing Our Services

We use your personal and financial information to analyse your retirement planning needs, develop personalised recommendations, implement agreed strategies, and provide ongoing support. This processing is necessary for performing our contract with you.

Communication

We use your contact details to respond to enquiries, schedule appointments, provide updates about your pension arrangements, and share information relevant to your retirement planning. We will only contact you about our services if you have expressly consented or where we have a legitimate interest in doing so.

Legal and Regulatory Compliance

As a regulated financial services firm, we are required to collect and retain certain information to comply with legal obligations including anti-money laundering regulations, Financial Conduct Authority requirements, and tax legislation.

Website Improvement

We analyse website usage data to understand how visitors interact with our site, identify technical issues, and improve our online services. This processing is based on our legitimate interest in providing an effective website.

Legal Basis for Processing

We process your personal data under several legal bases depending on the specific processing activity:

Contract performance: Processing necessary to provide the retirement planning services you have engaged us to deliver.

Legal obligation: Processing required to comply with financial services regulations, anti-money laundering requirements, and other legal obligations.

Consent: Where you have provided specific consent for particular processing activities, such as receiving marketing communications.

Legitimate interests: Processing necessary for our legitimate business interests, provided these do not override your fundamental rights and freedoms.

How We Protect Your Information

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction.

These measures include encrypted data transmission and storage, access controls limiting who can view personal information, regular security assessments and updates, secure document sharing platforms for sensitive information, and staff training on data protection responsibilities.

Despite our security measures, no internet transmission is completely secure. We cannot guarantee the absolute security of information transmitted to our website.

Who We Share Information With

We only share your personal information when necessary and appropriate:

Service Providers

We work with carefully selected third-party service providers who assist in delivering our services, including technology providers, document storage services, and professional advisors. These providers are contractually obligated to protect your information and may only use it for the specific purposes we authorize.

Pension Providers and Financial Institutions

When implementing retirement planning strategies on your behalf, we may need to share relevant information with pension providers, investment platforms, and other financial institutions. We only share information necessary for the specific transaction or service.

Regulatory and Legal Requirements

We may disclose personal information when required by law, regulation, legal process, or governmental request, or when necessary to protect our rights, property, or safety, or that of our clients or others.

International Transfers

We primarily store and process your personal information within the United Kingdom. If we need to transfer information outside the UK, we ensure appropriate safeguards are in place to protect your data in accordance with data protection legislation.

How Long We Keep Your Information

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, regulatory, accounting, or reporting requirements.

For client relationships, we typically retain records for at least six years after the relationship ends, as required by financial services regulations. Some records may be retained longer where necessary to defend potential legal claims or comply with regulatory requirements.

When personal information is no longer needed, we securely delete or anonymize it.

Your Rights

Under data protection legislation, you have several rights regarding your personal information:

Right of Access

You can request a copy of the personal information we hold about you, along with details about how we use it.

Right to Rectification

If personal information we hold is inaccurate or incomplete, you can request that we correct or complete it.

Right to Erasure

In certain circumstances, you can request that we delete your personal information. This right is not absolute and may not apply where we have legal obligations to retain information.

Right to Restrict Processing

You can request that we temporarily restrict how we use your information in certain circumstances.

Right to Data Portability

Where technically feasible, you can request that we provide your personal information in a structured, commonly used format or transmit it directly to another organization.

Right to Object

You can object to processing based on legitimate interests or for direct marketing purposes.

Right to Withdraw Consent

Where we process your information based on consent, you can withdraw that consent at any time. This does not affect the lawfulness of processing before consent was withdrawn.

Exercising Your Rights

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within one month, though this may be extended in complex cases.

We may need to verify your identity before fulfilling certain requests. If we cannot comply with your request, we will explain why.

Cookies and Tracking

Our website uses cookies and similar technologies. For detailed information about the cookies we use and how to manage them, please see our Cookies Policy.

Third-Party Websites

Our website may contain links to other websites. This Privacy Policy applies only to our website and services. We are not responsible for the privacy practices of other websites, and we encourage you to review their privacy policies.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post any changes on this page with an updated revision date. Significant changes will be communicated more prominently, such as through email notification to clients.

Your continued use of our services after changes are posted constitutes acceptance of the updated policy.

Children's Privacy

Our services are not directed at individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from someone under 18, we will delete it promptly.

Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

freshen-glow Limited
42 Kensington High Street
London, W8 4PF
United Kingdom
Email: [email protected]

Supervisory Authority

You have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection matters, if you believe we have not handled your personal information appropriately.

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Website: ico.org.uk