Introduction
This Privacy Policy explains how CDP Wealth (“we”, “us”, or “our”) collects, uses, stores, shares and protects your personal data when providing financial advice and related services. CDP Wealth Management is a trading name of Moneywise Financial Services Limited, registered in England and Wales company number 14954984, with registered office at 9a Purley Road, Purley, Surrey, CR8 2HA.
We are committed to protecting your personal information and respecting your privacy in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.
As a regulated financial services firm, we are also subject to rules and obligations imposed by the Financial Conduct Authority (“FCA”), including obligations relating to record keeping, client due diligence, anti-money laundering, and the provision of suitable financial advice.
This Privacy Policy explains:
What personal information we collect;
How and why we use it;
Who we may share it with;
How long we retain it;
Your rights regarding your personal information.
Who We Are
CDP Wealth acts as the Data Controller for the personal information you provide to us.
We may share personal data with our authorising network, ValidPath Limited, which may also act as a joint controller where required for regulatory supervision, compliance oversight and administration.
The Information We Collect
We may collect and process the following categories of personal data:
Name and title
Date of birth
Contact details including address, telephone number and email address
National Insurance number and identification documentation
Financial information including income, expenditure, assets, liabilities and tax status
Employment and business information
Banking and payment information
Pension, investment and insurance information
Family and dependant information where relevant
Marketing preferences
Website usage data, IP address and cookie information
Records of communications, meetings and correspondence
In some circumstances, we may also collect special category personal data, including information relating to your physical or mental health where relevant to the financial advice or services being provided.
How We Collect Information
We may collect personal information:
directly from you;
during meetings, telephone calls and electronic communications;
through forms and fact-finds you complete;
from product providers where authorised by you;
from professional advisers such as solicitors or accountants, where permission has been granted;
through website cookies and analytics technologies;
from identity verification and anti-fraud agencies, where legally permitted.
We may keep records or notes of conversations and meetings to maintain accurate records and comply with regulatory obligations.
How We Use Your Information
We use your information to:
provide financial advice and related services;
assess your financial needs and objectives;
make suitable product or service recommendations;
administer and manage your accounts;
communicate with you;
carry out identity verification, anti-money laundering and fraud prevention checks;
comply with legal and regulatory obligations;
maintain business records;
support compliance monitoring, quality assurance and business administration;
improve our services and systems;
send marketing communications where legally permitted.
We will only use your information where we have a lawful basis to do so.
Legal Bases for Processing
Under UK GDPR, we rely on one or more of the following lawful bases:
Contractual Necessity
Processing is necessary to provide the financial advice and services you request.
Legal and Regulatory Obligations
Processing is necessary to comply with legal and regulatory requirements, including obligations imposed by:
the Financial Conduct Authority (FCA);
anti-money laundering legislation;
fraud prevention regulations;
tax and accounting requirements.
Legitimate Interests
Processing is necessary for our legitimate business interests, provided those interests do not override your rights and freedoms.
Consent
In certain circumstances, particularly where special category data is involved, we will ask for your explicit consent before processing your information.
You may withdraw consent at any time, although doing so may affect our ability to provide certain services.
Special Category Personal Data
Some financial advice services require us to process special category personal data, including information relating to your health or medical history.
We will only collect and process this information where:
it is relevant and necessary for the services provided;
you have given explicit consent;
processing is otherwise permitted under applicable law.
Where additional categories of sensitive information become relevant, we will explain this clearly and obtain consent where required.
Sharing Your Information
In the course of providing our services, we may share your information with trusted third parties including:
ValidPath Limited;
pension, investment and insurance providers;
investment platforms;
pension transfer analysis providers;
compliance consultants and paraplanners;
IT, software and back-office system providers;
legal, regulatory and professional advisers;
fraud prevention and identity verification agencies;
HM Revenue & Customs, regulators or law enforcement bodies where required.
We will only share information necessary for the relevant purpose and require third parties to handle personal data securely and in accordance with applicable data protection laws.
We do not sell personal data to third parties.
International Transfers
Where personal data is transferred outside the United Kingdom or the European Economic Area (EEA), we will ensure appropriate safeguards are in place in accordance with UK data protection law.
Data Retention
We retain personal information only for as long as necessary:
to provide our services;
to comply with legal and regulatory obligations;
to resolve disputes;
to establish, exercise or defend legal claims.
As an FCA-regulated business, we may be required to retain certain records for extended periods in accordance with regulatory requirements.
Marketing Communications
Where legally permitted, we may send you information about services or products that may be relevant to you.
You can opt out of marketing communications at any time by:
using the unsubscribe link in emails; or
contacting us directly.
Website Support & Third-Party Service Providers
We may use trusted third-party service providers to support the operation, maintenance and security of our website and digital systems.
This may include website maintenance and technical support services provided by Rockpool Creative. In the course of providing these services, Rockpool Creative may have limited access to certain website-related data or systems strictly where necessary for maintenance, troubleshooting, updates, hosting support, security monitoring or technical administration.
Rockpool Creative acts solely on our behalf and only processes personal data in accordance with our instructions, applicable data protection legislation, and appropriate confidentiality and security obligations. They do not use personal data for their own marketing purposes or share such information with unauthorised third parties.
Any access to personal data is limited to what is reasonably necessary to provide technical and operational support services.
Cookies and Website Usage
Our website uses cookies and similar technologies to help provide a secure, efficient and user-friendly experience.
Cookies are small text files stored on your device when you visit a website. They help websites function correctly and provide information about how visitors interact with the site.
We use essential cookies that are necessary for the operation and security of the website, together with Google Analytics cookies to help us understand how visitors use our website. This information helps us improve website performance, content and user experience. The information collected is aggregated and does not generally identify individual visitors.
When you first visit our website, you may be presented with a cookie consent banner that allows you to manage your cookie preferences.
You can control or delete cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the website.
For further information about how Google processes information collected through Google Analytics, please visit Google's Privacy Policy.
Internet and Electronic Communications
Electronic communications, including email and internet transmissions, are not always secure.
While we take reasonable technical and organisational measures to protect your information, we cannot guarantee the security of data transmitted electronically and communications are therefore sent at your own risk.
If you prefer not to communicate electronically, please inform us.
Data Security
We maintain appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss or destruction.
Access to personal information is restricted to authorised individuals who require access for legitimate business purposes.
Your Rights
Under UK data protection law, you may have the right to:
access your personal information;
request correction of inaccurate data;
request erasure of your personal data;
restrict or object to processing;
request transfer of your information;
withdraw consent where processing relies on consent;
lodge a complaint with the Information Commissioner’s Office (“ICO”).
Please note that some rights may be limited where we are legally or regulatorily required to retain certain information.
To exercise your rights, please contact us using the details above.
You also have the right to complain to the Information Commissioner’s Office:
Information Commissioner’s Office (ICO)
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in legal, regulatory or operational requirements.
The latest version will always be available on our website.
Regulatory Information
CDP Wealth is an Appointed Representative of ValidPath Limited, which is authorised and regulated by the Financial Conduct Authority.
Financial Conduct Authority Firm Reference Number: 197107
Registered Office:
72A Chambers Avenue, Romsey, SO51 5BE
Registered in England and Wales. Company Number: 16884891.