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This Privacy Notice explains how we collect, use, share, store and protect your personal information – including where we use artificial intelligence (AI).
What information do we collect about you?
We collect information about you when you engage us for financial advice and planning services. This information may include:
Personal identifiers – details that help us to confirm who you are, such as:
- Your name, date of birth, address, contact details
- National Insurance number
- Identification documents (passport, driving licence)
Financial and professional information – information that helps us understand your financial position including:
- Your income and regular spending
- Details of your assets, liabilities, pensions & investments
- Tax information
- Bank account details
- Employment information
We may also need to use special category information, but only where relevant and with your explicit consent. This could include:
- Health information (for example, when providing insurance advice)
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Trade union membership
- Genetic information
- Biometric information (where used to identify someone, such as for access or payment purposes)
- Sex life information
- Sexual orientation information
Communications – to keep accurate records and meet regulatory requirements we may record:
- Emails, notes of telephone calls, meeting notes
- Records required to meet the FCA’s requirements
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
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 will use your information collected from the website to personalise your repeat visits to the site
Information about connected individuals
We may need to gather personal information about your close family members and dependants to provide our service to you effectively. In such cases, it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. If you act as a trustee or attorney, we may also need information about the relevant beneficiaries or donor(s).
We will 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?
We must have a lawful basis to process your personal data. Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:
We have a contractual obligation
This is the primary legal basis that we intend to use for processing your data. The personal information that we collect about you is essential for us to be able to effectively carry out the services that we have agreed to deliver to you.
We have a legal obligation
Sometimes, collecting personal data is needed to meet our legal and regulatory obligations. For example, UK anti money laundering legislation may require us to collect personal information to verify your identity.
We will obtain your consent
Special category data, such as that relating to health matters, is often required to provide our services. When this is required, we will obtain your explicit consent to collect and process this information. From time to time, we may wish to contact you to offer additional products or services which may be of interest to you. To do this, we will obtain your consent.
You may withdraw your consent at any time by notifying us at our main business address.
We have a legitimate interest
We rely on legitimate interest to retain relevant data for the purposes of assessing the appropriateness of our services, defending future complaints, and meeting our Professional Indemnity Insurer’s expectations.
How will we use the information about you?
We use your personal information to help us deliver the services you have asked for. This may include:
- Understanding your financial situation so we can give you the right advice
- Providing recommendations that meet FCA rules on suitability
- Applying for or arranging financial products on your behalf
- Carrying out identity, fraud and anti-money laundering checks
- Keeping accurate and compliant records
- Communicating with you about your services, plans, policies or investments
Who might we share your information with?
To deliver our services to you effectively, we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you. These may include:
- Financial product providers such as insurers, investment platforms and pension providers
- Compliance consultants, auditors and professional advisers who help us meet regulatory requirements
- Discretionary investment managers where relevant to your service
- IT service providers and secure cloud platforms that support our systems
- Regulators and authorities such as FCA, HMRC and the Financial Ombudsman Service
- Credit reference agencies, but only when necessary
We will never sell your personal information to anyone.
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 in line with our Security & Data Protection Policy.
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.
Using Artificial Intelligence (AI)
We may use AI tools to help us review information more efficiently and provide you with faster, more accurate services. The AI does not make decisions about you on its own – a human always checks the results.
When we do use AI:
Purpose: AI tools may be used for:
- Drafting or summarising internal documents (e.g. meeting notes)
- Identifying patterns or errors in data
- Enhancing compliance monitoring
- Supporting risk assessments or vulnerability detection (non-decision making)
We do not use any systems for making automated decisions. All outputs and decisions made by AI are subject to human review and approval before being used or relied upon.
Purpose and lawful basis for processing
The purpose and lawful basis for processing your personal information using AI, is for the performance of our service contract with you.
Human review
Any AI assisted output is reviewed by a human adviser before being used or relied upon.
Data sharing and storage
Where AI tools are used:
- We will ensure only the minimum necessary personal information is processed
- Anonymise or pseudonymise, where possible, personal information
- Ensure processing occurs in secure, regulated systems
- We have signed data processing agreements with all suppliers to ensure personal information is protected and that it cannot be used to improve their own AI products
- Personal information will not be transferred outside the UK/EEA without appropriate safeguards and consent being in place.
We do not use AI tools that use your personal information to train public models.
How long do we keep hold of your information?
During our relationship with you we will retain personal data which is necessary to provide services to you. We will take all reasonable steps to keep your personal data up to date throughout our relationship. We are 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
We also have to keep Identity- verification documents (required under Uk anti-money laundering rules) for:
- At least 5 years after our relationship with you ends
- Up to 10 years if we still have an ongoing relationship
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 is in our legitimate interest to do so.
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
Your data Protection rights?
You have several rights under data protection law. This helps you understand and control how your personal information is used:
- Right to be informed – You can ask us to explain how we collect, use, share and store your personal information
- Right of access – You can request a copy of the personal information we hold about you, along with details of how we use it
- Right to rectification – If you think any of your information is wrong or incomplete, you can ask us to correct or update it
- Right to erasure – In some situations, you can ask us to delete your personal information
- Right to restrict processing – You can ask us to limit how we use your information in certain circumstances
- Right to object – You can object to us using your personal information, for example for direct marketing
- Right to data portability – You can ask us to send your personal information to you, or directly to another organisation, in a structured, commonly used electronic format
- Rights related to automated decision making and profiling – If a decision about you is made without human involvement, you can challenge it and ask for someone to review it.
We will respond to any request you make about your data protection rights within one months. To make a request, please contact us using the contact details at the end of this privacy notice.
Marketing
We would like to send you information about our products and services which may be of interest to you. If you have agreed to receive marketing information, you may opt out later. 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 or post.
Cookies
We use cookies to track visitor use of the website and to compile statistical reports on website activity. You can set your browser not to accept cookies and the link below 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.
If you would like to learn more about cookies, you can visit https://www.allaboutcookies.org/ . You can change your browser settings to block or delete cookies at any time. The website above explains how to do this.
Other websites
Our website contains links to other websites. This privacy notice 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 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
Changes to our privacy notice
We keep our privacy notice under regular review and we will place any updated versions on our web page. We will inform you of any material changes when they occur. This privacy notice was last reviewed and updated on the 11th of May 2026.
How to contact us
Please contact us if you have any questions about our Privacy Notice or information we hold about you by email at enquiries@dbl-am.com or write to us at DBL Asset Management, 14 Kennerly’s Lane, Wilmslow, Cheshire SK9 5EQ.