Privacy Policy

Last updated: January 2024

At flickering-glade, we take the protection of your personal data seriously. This policy explains what information we collect, why we collect it, how we use it, and your rights regarding that information.

Who We Are

flickering-glade Ltd is the data controller responsible for your personal information. We are a financial management consultancy registered in England and Wales, operating from our office at 47 Gracechurch Street, London EC3V 0BT. For data protection enquiries, you can reach us at [email protected].

Information We Collect

The personal data we collect depends on how you interact with us. This may include:

• Contact details such as your name, email address, and postal address
• Professional information including job title, employer, and industry
• Financial information when you engage our services, such as income details, asset information, and business accounts
• Communications you send to us, including email correspondence and notes from meetings
• Technical data when you visit our website, including IP address, browser type, and pages visited

How We Collect Information

We gather personal data through several means:

• Directly from you when you contact us, request information, or engage our services
• Through our website when you browse pages or submit enquiries
• From third parties such as introducers or professional advisors working with you, always with appropriate consent
• From publicly available sources relevant to our advisory work

Legal Basis for Processing

We process personal information under several legal grounds recognised by UK data protection law:

• Contract performance: When processing is necessary to provide services you have requested
• Legitimate interests: When we have a business reason to process data that does not override your rights, such as improving our services or maintaining client relationships
• Legal obligation: When we must comply with regulatory requirements, including financial services regulations and anti-money laundering rules
• Consent: When you have specifically agreed to a particular use, such as receiving marketing communications

How We Use Your Information

We use personal data for the following purposes:

• Delivering the financial advisory and planning services you have engaged
• Responding to enquiries and communicating about our services
• Meeting our regulatory and legal obligations
• Improving our services based on feedback and usage patterns
• Protecting against fraud and ensuring the security of our systems
• Sending service-related communications such as appointment reminders

Sharing Your Information

We do not sell personal data to third parties. We may share information in limited circumstances:

• With service providers who assist our operations, such as IT support and cloud storage providers, under strict contractual obligations
• With your other professional advisors when you have instructed us to collaborate with them
• With regulatory bodies when required by law or professional obligations
• With law enforcement or government authorities when legally compelled

Data Retention

We retain personal information for as long as necessary for the purposes collected, taking into account:

• The duration of our business relationship with you
• Legal and regulatory requirements that may mandate specific retention periods
• Potential need to respond to future enquiries or legal claims
• Your instructions regarding deletion of your data

For most client data, we retain records for a minimum of six years following the end of our engagement, as required by financial services regulations. Website analytics data is typically retained for 26 months.

Your Rights

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

• Access: You can request a copy of the personal data we hold about you
• Rectification: You can ask us to correct inaccurate or incomplete data
• Erasure: In certain circumstances, you can request deletion of your data
• Restriction: You can ask us to limit how we use your data
• Portability: You can request your data in a machine-readable format
• Objection: You can object to processing based on legitimate interests
• Withdraw consent: Where processing is based on consent, you can withdraw it at any time

To exercise any of these rights, please contact us at [email protected]. We will respond within one month.

Security Measures

We implement appropriate technical and organisational measures to protect personal data, including:

• Encryption of data in transit and at rest
• Access controls limiting data access to authorised personnel
• Regular security assessments and updates
• Staff training on data protection responsibilities
• Secure disposal procedures for data no longer needed

International Transfers

We primarily store and process data within the United Kingdom. If data is transferred outside the UK, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the Information Commissioner's Office.

Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. Significant changes will be communicated through our website. We encourage you to review this policy periodically.

Complaints

If you have concerns about how we handle your personal data, please contact us first so we can address the issue. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection. Visit ico.org.uk for more information.

Contact Us

For questions about this policy or our data practices, please contact:

flickering-glade Ltd
47 Gracechurch Street
London EC3V 0BT
[email protected]