Söderberg & Partners Financial Planning Privacy Notice

(A) This Notice

This Notice is issued by Söderberg & Partners Financial Planning (“Söderberg & Partners”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including visitors to our Sites, our clients, personnel of corporate clients, vendors and our partners, applicants for employment, and visitors to our premises (together, “you”). Defined terms used in this Notice are explained in Section (P) below.

Söderberg & Partners provides financial planning, transactional advisory and arrangement and technology services (the “Services”) to retail and commercial clients in the United Kingdom. We partner with independent financial advisors who, in many cases, deliver the Services. In this context, Söderberg & Partners is the FCA authorised ‘principal’ and Söderberg & Partners’ partners act as our ‘appointed representatives’; and Söderberg & Partners and our partners will Process Personal Data as Joint Controllers. For more information about how Söderberg & Partners’ partners Process Personal Data in the context of the Services, please see the Partner Privacy Notice available on the website of your respective appointed representative.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice. 

This Notice was last updated on 8th May 2026.

(B)   Collection of Personal Data

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources: 

·       Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, in connection with our Services, or when you provide us with your business card, or when you submit a job application). 

·       Data we obtain in person: We obtain Personal Data during meetings, networking events, during visits from sales or marketing representatives, or at other events we attend.

·       Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a Service to you, or your employer).

·       Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).

·       Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site. 

·       Registration: We collect or obtain Personal Data when you use, or register to use, any of our Sites, or Services. 

·       Content and advertising information: If you interact with any third-party content or advertising on a Site (including third-party plugins and cookies), we receive Personal Data from the relevant third-party provider of that content or advertising. 

·       Personal Data from our partners: We receive Personal Data about you from our partners.

·       Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

(C)   Creation of Personal Data

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, meeting notes, call logs, call recordings, etc. We may also combine Personal Data from any of our Sites, or Services, including where those data are collected from different devices or sources.

(D)   Categories of Personal Data we Process

We Process the following categories of Personal Data about you: 

·       Personal details: given name(s); preferred name; photograph; national insurance number; and the same information relating to family members / dependants.

·       Contact details: correspondence address; telephone number; email address; details of personal assistants, where applicable; messenger app details; online messaging details; and social media details.

·       Correspondence: records and copies of your correspondence if you contact us.

·       Professional details: your CV; records of your expertise; professional history; practising details and qualification details; information about your experience; participation in meetings, seminars, advisory boards and conferences; information about your professional relationship with other individuals or institutions; language abilities; and other professional skills.

·       Identification documents: your passport; driving licence; other government issued identification documents; and proof of address (e.g., utility bills, mortgage statements, etc.). 

·       Demographic information: gender; date of birth / age; nationality; salutation; title; language preferences; and the same information relating to family members / dependants.

·       Visitor logs: records of visits to our premises.

·       Consent records: records of any consents you have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent).

·       Bank details: billing address; bank account information; BACS details; SWIFT details; and IBAN details.

·       Financial information: information relating to financial status, including investments, assets, income, and liabilities; risk appetite; and investment objectives.   

·       Background checks: information surfaced by ‘Know Your Client’ checks / credit checks (e.g., details of bankruptcies, county court judgements, etc.).

·       Correspondence and meeting notes: records and copies of your correspondence; meeting notes; logs of telephone calls; and telephone recordings.

·       Data relating to our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; registration details; username; password; security login details; usage data; and aggregate statistical information.

·       Employer details: where you interact with us in your capacity as an employee of a third party; and the name, address, telephone number and email address of your employer, to the extent relevant.

·       Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.

·       Security information: your password(s); login attempt details; security settings; and other security-related information.

·       Cookie data: we collect information via cookies and similar technologies. Please see our [Cookie Policy for more details.

·       Views and opinions: any views and opinions that you choose to send us, or publicly post about us on social media platforms.

(E)   Sensitive Personal Data

We may request Sensitive Personal Data from you in connection with the provision of certain Services. In particular, we may Process information relating to criminal convictions during the course of conducting background checks, including in the context of recruitment. We may also Process details of current and/or former health conditions in the context of advising on life insurance and income protection products, and/or in the context of financial planning services (i.e., where your medical conditions may inform your investment objectives).

Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

·       Compliance with applicable law: we may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations). 

·       Detection and prevention of crime: we may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud). 

·       Establishment, exercise or defence of legal claims: we may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal claims.

·       Consent: we may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

(F) Purposes of Processing and legal bases for Processing

(G)   Disclosure of Personal Data to third parties

We disclose Personal Data to other entities within our group, for legitimate business purposes and the operation of our Sites, or Services to you, in accordance with applicable law. In addition, we disclose Personal Data to: 

• our partners;
• our accountants, auditors, consultants, lawyers and other outside professional advisors, subject to binding contractual obligations of confidentiality;
• third-party Processors (such as payment services providers; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties; 
• any relevant third-party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
• any relevant third-party provider, where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third-party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law. 

(H)   Profiling

We Process Personal Data for the purposes of automated decision-making and Profiling, which is carried out for the following purposes:

(I)   International transfer of Personal Data

Because of the international nature of our business, we transfer Personal Data within our group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Notice. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. 

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses or the UK equivalent (i.e., the UK International Data Transfer Agreement / UK addendum to the Standard Contractual Clauses). You are entitled to request a copy of our Standard Contractual Clauses or the UK equivalent (i.e., the UK International Data Transfer Agreement / UK addendum to the Standard Contractual Clauses) using the contact details provided in Section (P) below. 

Please note that when you transfer any Personal Data directly to any group entity established outside the UK or the EEA (as applicable), we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.

(J)   Data security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law. 

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely. 

(K)   Data accuracy

We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up-to-date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

(L)   Data minimisation

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice. 

(A)   Data retention

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows: 

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the relevant Personal Data; or
• anonymize the relevant Personal Data.

(N)   Your legal rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

·       the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, or Services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);

·       the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;

·       the right to request rectification of any inaccuracies in your Relevant Personal Data;

·       the right to request, on legitimate grounds:

o    erasure of your Relevant Personal Data; or

o    restriction of Processing of your Relevant Personal Data;

·       the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable; 

·       where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and

·       the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (i.e., in relation to the UK, the Information Commissioner’s Office (https://ico.org.uk/) or in relation to the EU, the Data Protection Authority for EU Member State in which you live, or in which you work, or in which the alleged infringement occurred (see the list here: https://edpb.europa.eu/about-edpb/about-edpb/members_en)).

This does not affect your statutory rights. 

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (P) below. Please note that: 

• in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and 
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

(D)   Direct marketing

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, or Services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, or Services. If we provide Sites, or Services to you, we may send or display information to you regarding our Sites, or Services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law. 

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. Please note that it may take up to 2 weeks to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, or Services you have requested. 

(P)   Definitions 

• “Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
• “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
• “EEA” means the European Economic Area.
• “FCA” means the Financial Conduct Authority, the independent statutory body responsible for regulating the financial services industry in the UK.
• “GDPR” means the General Data Protection Regulation (EU) 2016/679.
• “Joint Controller” means a party that acts as a Controller, in concert with one or more other Controllers, to determine the purposes and means of a given Processing activity.
•  “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
•  “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
• “Relevant Personal Data” means Personal Data in respect of which we are the Controller. 
• “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.
• “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
•  “Site” means any website operated, or maintained, by us or on our behalf. 
• “UK GDPR” has the meaning given to it in section 3(10) of the Data Protection Act 2018.
•  “UK International Data Transfer Agreement” means the template transfer agreement adopted by the UK Information Commissioner’s Office on 21 March 2022.