Privacy Notice

Forte Financial LLP
85 Great Portland Street, First Floor, London, England, W1W 7LT
+44 20 37328 8370
info@forte-financial.co.uk
Company number: OC377808

As an Appointed Representative of SJP, we operate under the regulatory supervision and permissions of:

St. James’s Place Wealth Management plc
St. James’s Place House, 1 Tetbury Road, Cirencester GL7 1FP

Depending on the services you require, we may collect and process the following categories of personal data:

2.1 Personal identification information

• Full name

• Date of birth

• Residential address

• Email address

• Telephone numbers

• National Insurance number

• Citizenship or residency information

2.2 Financial and investment information

• Income, assets, liabilities, and expenditure

• Tax residency and tax reference numbers

• Investment history and portfolio details

• Retirement planning details

• Source of funds and source of wealth

• Personal financial objectives and risk tolerance

2.3 Special category data (only where strictly necessary)

• Health information related to insurance underwriting

• Medical reports (with your explicit consent)

2.4 Technical and website use data

• IP addresses

• Cookies and usage analytics (website only)

2.5 Communication records

• Meeting notes, emails, telephone recordings where applicable

• Documents shared during the advice process

We collect personal information:

• Directly from you during meetings, calls, emails, and online submission forms

• From third parties with your consent (e.g., product providers, accountants, solicitors)

• From publicly available sources for verification purposes

• Through SJP administration systems used for delivering products and services

• Via anti–money laundering and identity-verification services

We process your data for the following purposes:

4.1 To provide financial advice and planning services

• Assessing suitability and risk profile

• Preparing recommendations and reports

• Managing investments and policies

• Providing ongoing review services

4.2 To fulfil our legal and regulatory obligations

Including those under:

• Financial Conduct Authority (FCA) rules

• Anti-money laundering (AML) regulations

• Tax reporting requirements

• SJP oversight and compliance standards

4.3 For business administration

• Scheduling appointments

• Processing payments

• Maintaining accurate records

• Monitoring quality and compliance

4.4 With your consent

• Marketing communications

• Sharing sensitive (special category) data when required

• Passing your information to professional third parties (e.g., solicitors)

We will never sell your data or use it for unrelated purposes.

We rely on the following legal grounds:

1. Performance of a Contract
   To provide advice, arrange financial products, and deliver ongoing services.

2. Compliance with Legal Obligations
   Anti-money laundering, FCA rules, record-keeping, audit requirements.

3. Legitimate Interests
   Business administration, service improvement, risk management.

4. Consent (used sparingly)
   For marketing or processing health information for insurance purposes.

Where consent is relied upon, you have the right to withdraw it at any time.

We may share your personal data with:

• St. James’s Place Wealth Management plc (joint controller)

• SJP product and platform providers

• Insurers and investment providers

• Anti-money-laundering verification providers

• Compliance consultants and auditors

• Third-party IT, secure storage, and cloud service providers

• Professional advisers (e.g., solicitors, tax specialists) where you have authorised us to do so

We require all third parties to maintain strict confidentiality and data security standards.

Where your data is transferred outside the UK or EEA (for example, for cloud storage or outsourced services), we ensure:

• Adequacy regulations are in place, or

• Standard Contractual Clauses (SCCs) or equivalent safeguards are implemented.

We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including:

• Regulatory record-keeping (typically 6–15 years depending on the product type)

• Lifetime retention for certain pension or investment advice records

• Longer periods where required by law or industry guidance

Once data is no longer required, it will be securely deleted or anonymised.

Under the UK GDPR, you have the right to:

• Access your personal data

• Rectify inaccurate or incomplete data

• Erase personal data (subject to regulatory requirements)

• Restrict or object to processing

• Data portability for the information you have provided

• Withdraw consent at any time (where consent is the legal basis)

To exercise your rights, please get in touch with us at: info@forte-financial.co.uk

We implement appropriate technical and organisational measures to protect your data, including:

• Secure encrypted systems

• Access controls and authentication

• Staff training and confidentiality agreements

• Regular security audits

• Encrypted communications wherever possible

Despite our precautions, no transmission of data over the internet can be guaranteed as completely secure.

We may contact you regarding:

• Financial updates

• Regulatory changes

• Invitations to events

• New services relevant to your financial planning

You may opt out at any time by contacting us or using unsubscribe options.

We will never send unsolicited marketing messages.

If you have concerns about how your data is used, please contact:

Data Protection Officer
Forte Financial LLP
85 Great Portland Street, First Floor, London, England, W1W 7LT
info@forte-financial.co.uk

You also have the right to lodge a complaint with:

Information Commissioner’s Office (ICO)
www.ico.org.uk
0303 123 1113

We may update this Privacy Notice from time to time to reflect legal, regulatory, or business changes. The latest version will always be available on our website or upon request.

For questions, concerns, or to exercise your data rights, contact:

Forte Financial LLP
85 Great Portland Street, First Floor, London, England, W1W 7LT
+44 20 3728 8370, info@forte-financial.co.uk