Privacy Policy

Astute Private Wealth Ltd – Privacy Notice

Astute Private Wealth Ltd is directly authorised by the Financial Conduct Authority. This Privacy Notice explains how we collect, use, share, store and protect personal information about you when we provide financial planning, mortgage advice and related services. It also explains your date protection rights and how to contact us if you have any questions or concerns.

We take your privacy seriously and are committed to handling personal information lawfully, fairly and transparently under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

What Information Do We Collect About You?

We collect information about you when you engage us for financial planning, mortgage advice or related services. This information will usually relate to your personal and financial circumstances and may include:

• Personal Identifiers: Your name, date of birth, National Insurance number, address, contact details and copies of identity documents such as a passport or driving licence.
• Financial and Professional Information: Details of your income, expenditure, assets, liabilities, pensions, investments, tax position, bank details and employment information.
• Advice and Service Information: Details about your objectives, circumstances, risk profile, capacity for loss, product applications, recommendations, policies, plans, investments and employment information.
• Communications and Records: Emails, letters, notes of telephone calls and meetings, electronic messages, file notes, instructions and records required to meet our regulatory obligations.
• Website and Cookies Information: Standard internet log information and visitor behaviour information collected through cookies when you use our website.

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

Where necessary for the provision of our services, we may collect and use special category personal data. This may include information about your health, for example, where this is relevant to advice, vulnerability support, capacity, affordability, estate planning or wider financial planning. We will only use this information where relevant and where we have an appropriate lawful basis, which may include your explicit consent.

How Do We Collect Your Personal Information?

We collect personal information from a range of sources, including:

• Directly from you during meetings, telephone calls, video calls, emails, letters, forms, questionnaires and secure online processes.
• From documents you provide to us, such as, identification documents, statements, policy documents, tax information and financial records.
• From product providers, platforms, lenders, insurers, investment managers, solicitors, accountants, attorneys, trustees, representatives or other professional advisers where relevant to the services we provide.
• From third party agencies used for identity verification, anti-money laundering, fraud preventions or financial crime checks.
• From our website, where cookies or similar technologies are used.
• From feedback surveys or other communications you choose to provide.

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. If you act as an attorney, trustee, executor, representative or in another capacity for someone else, we may also need information about donors, beneficiaries, settlors, trustees, attorneys, executors or other connected parties.

Where you provide personal information about another person, you should ensure that you have their authority or other appropriate basis to do so. We will make this Privacy Notice available to them or, where appropriate, ask you to pass the privacy information to them.

Why Do We Need to Collect and Use Your Personal Data?

We must have a lawful basis to process your personal data. Under the UK GDPR, the lawful bases we are most likely to rely on are:

• Contractual Obligation: This is the primary basis we use when personal information is needed to provide the services we have agreed to deliver to you.
• Legal Obligation: Sometimes we need to collect or retain personal information to meet legal and regulatory duties, including FCA rules, anti-money laundering requirements and financial crime obligations.
• Consent: We may ask for your consent where required, including explicit consent for certain special category information. You may withdraw consent at any time by contacting us, although this will not affect processing carried out before consent was withdrawn.
• Legitimate Interests: We may use or retain relevant information where we have a legitimate business reason to do so, including assessing the appropriateness and suitability of our services, responding to queries or complaints, defending future claims and meeting our Professional Indemnity insurer’s expectations.
• Recognised Legitimate Interests: In limited circumstances, we may rely on recognised legitimate interests for specific public-interest purposes, such as fraud prevention or safeguarding, where this is necessary and appropriate.

How Will We Use the Information About You?

We use your personal information to provide you with the services for which you engage us. This may include:

• Understanding your financial position, objectives, needs, preferences and circumstances.
• Providing advice and recommendations that meet regulatory requirements, including suitability requirements.
• Applying for, arranging, reviewing or administering financial products, policies, investments, mortgages or related services on your behalf.
• Carrying out identity, verification, fraud prevention, anti-money laundering and financial crime checks.
• Keeping accurate and compliant records of the advice and services we provide.
• Communicating with you about your services, plans, policies, investments, reviews or other relevant matters.
• Responding to queries, complaints, regulatory requests, legal obligations or professional adviser requests.
• Improving our service, training staff, monitoring quality and maintaining appropriate governance and compliance records.

Who Might We Share Your Information With?

In order to deliver our services to you effectively, we may share your personal information with trusted third parties where this is necessary and lawful. These may include: 

• Financial product providers, investments platforms, pension providers, insurers, mortgage lenders and discretionary investment managers.
• Professional compliance consultants, auditors, accountants, solicitors, legal advisers and other professional advisers.
• Technology providers, IT support providers, secure cloud platforms and software providers that support our systems and processes.
• Regulators, Ombudsman services, law enforcement agencies, HMRC, the FCA, Financial Ombudsman Service or other authorities where required or appropriate.
• Credit reference agencies, identity verification providers and financial crime prevention agencies where necessary.
• Other persons or organisations where you have asked us to share information, or where sharing is necessary to provide the services you have requested.

We do not sell your personal information to anyone.

Where third parties process your data on our behalf, we will have appropriate contractual arrangements in place to ensure that the nature and purpose of the processing is clear, that they are subject to appropriate confidentiality and security obligations, and that they only act in accordance with our written instructions.

Where it is necessary for your personal data to be forwarded to a third party, we will use appropriate security measures to protect your personal data in transit, for example, password protection, encryption or secure portals.

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

Using Artificial Intelligence (AI) and Automated Tools

We may use Artificial Intelligence (AI), automated software tools and other digital systems to support the efficient delivery, administration, monitoring and review of our services. These tools may be used to assist with activities such as, drafting or summarising internal documents, analysing information already held on client files, identifying potential gaps or errors in data, supporting compliance monitoring, preparing management information and improving operational controls.

We do not use systems that make decisions about you without human oversight. AI and automated tools are used as support tools only. Any output from these tools is reviewed by an appropriately trained member of staff before being used or relied upon.

Where AI or automated tools are used, we will seek to process only the minimum personal information necessary for the relevant purpose. Where appropriate, we will anonymise or pseudonymise information and use secure, controlled systems. We do not use client personal information to train public AI models.

If our use of AI or automated decision-making changes in a way that materially affects how we use your personal information, we will update this Privacy Notice.

International Transfers

Some of the third party systems or service providers we use may process or store personal information outside the United Kingdom. Where this occurs, we will take steps to ensure that appropriate safeguards are in place, such as, adequacy arrangements, standard contractual clauses, international data transfer agreements or other safeguards required by data protection law.

Recording Telephone Calls

We record telephone calls to ensure the quality of our service, to help with staff training, and to keep a record of important discussions or instructions. Access to call recordings is limited to authorised staff and only when necessary, for example, to handle a complaint or carry out an internal review.

How Long Do We Keep Hold of Your Information?

During the course of our relationship with you, we will retain personal data that is necessary to provide our services to you. We will take reasonable steps to keep your personal data accurate and up to date throughout our relationship.

We are also subject to regulatory requirements to retain your data at the end of the relationship for specified minimum periods. Generally, these are:

• 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 or regulatory obligation to retain your records. We also retain certain identity verification records and related information to comply with anti-money laundering legislation and other legal obligations.

We may retain personal data for longer where this is necessary for legal, regulatory or legitimate business reasons, including where information may be required to respond to a future complaint, claim, regulatory enquiry or insurer request. We will not keep personal information for longer than necessary and will review retention periods by reference to the purpose for which the information is held.

You have the right to request deletion of you personal data. We will comply with this request where we are able to do so, subject to any legal, regulatory or legitimate business reasons requiring us to retain the information.

Your Data Protection Rights

You have several rights under data protection law. These rights help you understand and control how your personal information is used. They include:

• Right to Be Informed: You have the right to be told how we collect, use, share, store and protect your personal information.
• Right of Access: You can request a copy of the personal information we hold about you.
• Right to Rectification: You can ask us to correct personal information that you believe is inaccurate or incomplete.
• Right to Erasure: You can ask us to delete your personal information in certain circumstances.
• Right to Restrict Processing: You can ask us to limit how we use your personal information in certain circumstances.
• Right to Object: You can object to us using your personal information in certain circumstances, including where we rely on legitimate interests or use your information for direct marketing.
• Right to Data Portability: Where this right applies, you can ask us to provide personal information you have given us in a structured, commonly used and machine-readable format, or ask us to transfer it to another organisation.
• Rights Related to Automated Decision-Making and Profiling: If a significant decision about you is ever made without meaningful human involvement, you have the right to request human review, ask for an explanation and challenge the decision.

If you would like to exercise any of these rights, please contact us using the details at the end of this notice. We will respond to your request within the timescales required by data protection law.

Marketing

We do not actively send any marketing information about our products and services to clients. However, if this position changes and we decide to send you any marketing information at any future time, you will have the opportunity to opt out.

You have the right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If at any time in the future you no longer wish to be contacted for marketing purposes, please contact us by email or post.

Cookies

We use cookies to track visitor use of the website and to compile statistical reports on website activity. Cookies are text files placed on your computer or device to collect standard internet log information and visitor behaviour information. We may use this information to help us understand how visitors use our website and to improve our site.

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

You can set your browser not to accept cookies and the website above explains how to remove cookies from your browser. Please note that if you choose to block cookies, some parts of our website may not work as expected.

Other Websites

Our website may contain links to other websites. This Privacy Notice only applies to our website, so when you link to other websites you should read their own Privacy Notices.

What Can You Do If You Are Unhappy With How Your Personal Data is Processed?

If you have any concerns about how we use your personal information, please contact us using the details below. You do not need to follow a specific process or use particular wording. You can raise a concern or complaint through any of our usual contact channels, including email, telephone or post.

We will consider your concern, investigate where appropriate and respond as soon as reasonably practicable. If you are not satisfied with our response, you have the 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

Telephone: 0303 123 1113 (local rate)

Website: https://ico.or.uk/make-a-complaint/

Changes to Our Privacy Notice

We keep our Privacy Notice under regular review and will update it where necessary. This Privacy Notice was last updated on 12 August 2026.

How to Contact Us

Please contact us if you have any questions about this Privacy Notice or the personal information we hold about you:

By email at: infochester@astutepwltd.co.uk & infoliverpool@astutepwltd.co.uk
Or write to us at: Astute Private Wealth Ltd
Chester Office: 2nd Floor, Vista Building, St. David’s Park, Ewloe, Flintshire CH5 3DT
Liverpool Office: 5th Floor, 4 St Paul’s Square, St Paul’s Square, Liverpool L3 9SJ