PRIVACY NOTICE

About this privacy notice

This Privacy Notice explains how Cross Keys Wealth LLP collects, uses, stores and protects your personal information.

We are committed to protecting your privacy and processing your personal information fairly, lawfully and transparently in accordance with UK data protection legislation.

Our contact details

Firm Name: Cross Keys Wealth LLP

Address: PO Box 81616, LONDON, SW11 9UD

Email: contact@crosskeyswealth.co.uk

What personal information we collect

To provide financial advice and related services, we may collect and process the following information:

Personal information

• Name, address and contact details
• Date of birth
• National Insurance number
• Marital or family circumstances
• Employment and occupation details
• Identification documents, including passports and driving licences
• Bank account details
• Financial information, including:
  • Income and expenditure
  • Assets and liabilities
  • Savings and investments
  • Pension arrangements
  • Insurance policies
  • Tax information

Special category information

Where relevant and necessary, we may collect special category information, including:

• Health information
• Vulnerability-related information
• Information relating to powers of attorney or court-appointed representatives

We will only process special category information where we have a lawful basis to do so and, where required, your explicit consent.

Communications

To maintain accurate records and meet regulatory requirements, we may retain:

• Emails
• Letters
• Meeting notes
• Telephone records
• Video meeting records
• Messages received through client portals or electronic communication systems

How we collect your information

We may collect information directly from:

• You
• Joint applicants
• Attorneys acting on your behalf
• Trustees or executors
• Company directors or authorised representatives

We may also collect information from third parties where authorised or required, including:

• Product providers
• Pension providers
• Investment platforms
• Discretionary fund managers
• Employers
• Accountants
• Solicitors
• Credit reference agencies
• Identity verification providers
• Regulatory bodies

How we use your information

We use your information to:

• Provide financial planning and advice services
• Assess your needs and objectives
• Make recommendations that are suitable for your circumstances
• Arrange products and services on your behalf
• Service existing arrangements
• Communicate with you regarding your plans, policies and investments
• Process client instructions
• Verify your identity
• Undertake anti-money laundering checks
• Prevent fraud and financial crime
• Maintain business records
• Respond to complaints
• Meet legal and regulatory obligations

Our lawful basis for processing

Data protection legislation requires us to have a lawful basis for processing personal data.

Depending on the circumstances, we may rely upon:

Contract

Processing necessary to provide the services you have requested.

Legal obligation

Processing required to meet legal or regulatory obligations, including FCA and anti-money laundering requirements.

Legitimate interests

Processing necessary for our legitimate business interests, including:

• Compliance monitoring
• Professional indemnity requirements
• Business administration
• Complaint handling
• Quality assurance
• Risk management

Consent

Where special category data is required, we may rely upon your explicit consent.

You may withdraw consent at any time; however, this may affect our ability to provide certain services.

Who we share your information with

We only share information where necessary and appropriate.

This may include:

• Financial product providers
• Investment platforms
• Pension providers
• Insurers
• Custodians
• Compliance consultants
• Auditors and professional advisers
• Legal advisers
• Accountants
• IT support providers
• Secure cloud service providers
• Regulators and authorities, including:
  • Financial Conduct Authority (FCA)
  • HM Revenue & Customs (HMRC)
  • Financial Ombudsman Service (FOS)
  • Information Commissioner's Office (ICO)
• Identity verification and anti-financial crime service providers

We never sell your personal information to third parties.

International transfers

In some circumstances, your information may be transferred outside the United Kingdom.

Where this occurs, we will ensure appropriate safeguards are in place to protect your data and meet UK data protection requirements.

Use of artificial intelligence

We may use AI-assisted tools to support administrative, research and compliance functions.

Examples may include:

• Summarising meeting notes
• Conducting research
• Identifying errors or inconsistencies
• Supporting compliance monitoring

Where AI tools are used:

• Appropriate security controls are applied.
• Access to personal information is restricted.
• Information is only processed where appropriate and necessary.
• AI-generated outputs are reviewed by a suitably trained individual.
• We do not make decisions about you based solely on automated processing.

How we protect your information

We maintain appropriate technical and organisational measures to safeguard personal information.

These measures include:

• Access controls
• Encryption where appropriate
• Secure storage systems
• Staff training
• Supplier due diligence
• Confidentiality obligations

How long we keep your information

We retain information only for as long as necessary to meet legal, regulatory and business requirements.

How long we keep personal information depends on why we collected it, the services we provide, applicable legal and regulatory record-keeping requirements, and whether the records may reasonably be needed to investigate or respond to a regulatory complaint or claim concerning advice or other regulated activities. We document and review our retention periods and do not keep information simply because it may be useful in future.

These are typical minimum periods only. A longer period may be appropriate where the firm needs to retain records to meet another regulatory requirement or to investigate, evidence or respond to a regulatory complaint or claim concerning advice or other regulated activities. When information is no longer required, we will securely delete, destroy or anonymise it. In some circumstances, we may retain the information but restrict its processing. This means that we continue to store it, but do not otherwise use it except where permitted by law or necessary to deal with the relevant regulatory matter.

Information about connected individuals

Where you provide information relating to another individual, such as a spouse, partner, dependant, trustee or attorney, you should ensure they are aware that you have provided their information to us.

We may provide them with a copy of this Privacy Notice where appropriate.

Your rights

Under UK data protection legislation, you have the right to:

• Be informed about how your information is used
• Access your personal information
• Correct inaccurate information
• Request deletion of information in certain circumstances
• Restrict processing in certain circumstances
• Object to processing in certain circumstances
• Request transfer of your data to another organisation
• Challenge certain automated decision-making activities

Requests can be made using the contact details provided above.

We will normally respond within one month.

Marketing

We may occasionally contact you with information regarding our services that may be relevant to you.

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

We will not share your information with unrelated third parties for marketing purposes without your consent.

Cookies and website use

Our website uses cookies and similar technologies. Essential cookies keep the site secure and working. With your consent, we also use analytics cookies (Google Analytics) to understand how the site is used, and advertising cookies (Meta) to measure the performance of our adverts. We rely on your consent for these, and you can withdraw it at any time using the cookie settings link in the footer of our website. Google and Meta process this information under their own privacy policies.

Further information is available in our Cookie Policy.

Other websites

Our website may contain links to third-party websites. We are not responsible for their privacy practices. You should review the privacy notice of any external website you visit.

Complaints

If you have concerns about how we handle your personal information, please contact us first using the details set out above.

You also have the right to complain to the Information Commissioner's Office.

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint/data-complaints-complaints/

ICO relocation notice

The ICO has announced that it intends to relocate its head office to the Circle Square development on Oxford Road, Manchester, during autumn 2026.

Changes to our privacy notice

We keep our privacy policy under regular review and we'll place any updates on our website and inform you of any changes when they occur.

Last updated: 19 October 2026