Privacy Policy

Last updated: January 2024

At shrouded-frost, we take the privacy of our clients and website visitors seriously. This policy explains what information we collect, how we use it, and your rights regarding your personal data.

Who We Are

shrouded-frost is a trading name of Pemberton Financial Consultancy Ltd, registered in England and Wales (Company Number: 09847621). Our registered address is 47 Pemberton House, Victoria Street, London SW1E 5NE.

For privacy-related enquiries, contact us at [email protected].

Information We Collect

We collect information in several ways depending on how you interact with us:

Information You Provide Directly

When you enquire about our services or become a client, you may provide:

• Name and contact details (email address, postal address)
• Financial information necessary for our consultancy services
• Employment and income details
• Information about your financial goals and circumstances
• Any other information you choose to share during our consultations

Information Collected Automatically

When you visit our website, we may automatically collect:

• Technical information including IP address, browser type, and operating system
• Information about your visit including pages viewed and time spent
• Referring website information

How We Use Your Information

We use your personal information for the following purposes:

• Providing our financial consultancy services
• Responding to your enquiries and requests
• Sending service-related communications
• Improving our website and services
• Complying with legal and regulatory obligations
• Protecting our legitimate business interests

Legal Basis for Processing

We process your personal data under the following legal bases:

• Contract: Processing necessary to provide our services to you
• Legitimate interests: Processing necessary for our legitimate business purposes, such as improving our services and marketing
• Legal obligation: Processing required to comply with applicable laws
• Consent: Where you have given specific consent for processing, such as marketing communications

Data Sharing

We do not sell your personal information. We may share your data with:

• Service providers who assist with our business operations (such as IT support and professional advisers)
• Regulatory bodies and law enforcement when required by law
• Professional partners to whom you have asked us to refer you

All third parties with whom we share data are required to maintain appropriate security measures and can only use your data for specified purposes.

Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive data in transit and at rest
• Secure access controls and authentication
• Regular security assessments and updates
• Staff training on data protection practices

Data Retention

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

• Client records: Retained for 7 years after the end of our business relationship to comply with regulatory requirements
• Enquiry records: Retained for 2 years if you do not become a client
• Website analytics: Retained for 26 months

Your Rights

Under data protection law, you have rights including:

• Access: Request a copy of the personal data we hold about you
• Rectification: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your data in certain circumstances
• Restriction: Request limitation of how we use your data
• Portability: Request transfer of your data to another organisation
• Objection: Object to certain types of processing
• Withdraw consent: Where processing is based on consent, withdraw it at any time

To exercise any of these rights, contact us at [email protected]. We will respond within one month.

International Transfers

Your data is primarily stored and processed within the United Kingdom and European Economic Area. If we transfer data outside these regions, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by relevant authorities.

Complaints

If you have concerns about how we handle your personal data, please contact us first so we can address them. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

Changes to This Policy

We may update this privacy policy from time to time. Significant changes will be communicated to clients directly. The date at the top of this page indicates when it was last revised.

Contact Us

For questions about this policy or our privacy practices, contact us at:

Email: [email protected]
Address: 47 Pemberton House, Victoria Street, London SW1E 5NE