Lucent Financial Planning Ltd is authorised and regulated by the Financial Conduct Authority. This Privacy Notice explains how we use any personal information we collect about you.

What information do we collect about you?

We collect information about you when you engage us for investment/pension/mortgage and protection advice. This information will relate to your personal and financial circumstances.  It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.

We may also collect information when you voluntarily complete client surveys or provide feedback to us.

Information about connected individuals

We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this Privacy Notice for them or, where appropriate, ask you to pass the privacy information to them.

Why do we need to collect and use your personal data?

The primary legal basis we intend to use for the processing of your data is for the performance of our contract with you. The information we collect about you is essential for us to be able to carry out the services you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.

Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.

How will we use the information about you?

We collect information about you in order to provide you with the services for which you engage us.

Who might we share your information with?

If you agree, we may email you about other products or services we think may be of interest to you.

We won’t share your information for marketing purposes with other companies.

In order to deliver our services to you effectively, we may send your details to third parties such as those we engage for professional compliance, accountancy or legal services, as well as product and platform providers we use to arrange financial products for you.

Where third parties are involved in processing your data we’ll have a contract in place with them to ensure the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.

Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime, we may send your details to third party agencies for identity verification purposes.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing

1. Sending you a newsletter via email by using the ‘Sign up to our newsletter’ function on the Website

2. Providing your name, telephone number and email address in the ‘Request a callback’ function on the Website

3. When you contact us via email by clicking on the email address links or ‘get in touch’ links on the Website

Identity

Contact

Profile

Marketing and Communications

Consent
To discharge our duties as your adviser

All information necessary to act as your financial adviser, including, but not limited to:

Identity

Contact

Profile

Financial

Employment

Performance of contract

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

Identity

Contact

Profile

Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to complete a survey

Identity

Contact

Profile

Usage

Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Identity

Contact

Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Website content to you and measure or understand the effectiveness of the content we serve to you

Identity

Contact

Profile

Usage

Marketing and Communications

Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences

Technical

Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you

Identity

Contact

Technical

Usage

Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

How long do we keep hold of your information?

During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up-to-date throughout our relationship.

We’re also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:

  • Five years for investment business
  • Three years for mortgage business
  • Indefinitely for pension transfers and opt-out business
  • Three years for insurance business

These are minimum periods, during which we have a legal obligation to retain your records.

We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so.  In any case, we’ll not keep your personal data for longer than the regulatory requirements after our relationship with you has ended.

You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

How can I access the information you hold about me?

You have the right to request a copy of the information we hold about you. If you’d like a copy of some, or all of your personal information, please email or write to us using the contact details noted below.

When your personal data is processed by automated means, you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure your personal information is accurate and up to date. Please ask us to correct or remove any information you think is incorrect.

Marketing 

We’d like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email (info@lucentfinancialplanning.co.uk) or post, or by clicking here.

Cookies

Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.

We use cookies to track visitor use of the website and to compile statistical reports on website activity.

For further information visit http://www.allaboutcookies.org/

You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Other websites

Our website contains links to other websites.  This Privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

What can you do if you are unhappy with how your personal data is processed?

You also have a right to lodge a complaint with the supervisory authority for data protection.  In the UK this is:-

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

0303 123 1113 (local rate)

Changes to our Privacy policy

We keep our privacy policy under regular review and we’ll place any updates on this web page (and/or) inform you of any changes when they occur.  This Privacy policy was last updated on 23rd March 2022.

How to contact us

If you have any questions about our Privacy policy or information we hold about you, or to raise a complaint, please contact us in writing:

– via email at info@lucentfinancialplanning.co.uk

– or write to us at Lucent Financial Planning Ltd, 1b The Exchange, 20a Poplar Rd, Solihull, B91 3AB.

Person responsible: Steven Rowe, Director – info@lucentfinancialplanning.co.uk / 0121 705 1000