Privacy Policy

Introduction

dreamshade-pond Limited ("we", "us", or "our") is committed to protecting the privacy and security of your personal information. This privacy policy explains how we collect, use, store, and share information about you when you use our website or engage with our pension planning and retirement advisory services.

We are registered as a data controller with the Information Commissioner's Office (ICO) under registration number ZB847392. Our registered office is at 47 Threadneedle Street, London, EC2R 8AU, United Kingdom.

Information We Collect

The personal information we collect about you depends on the nature of your interaction with us. We may collect the following categories of information:

Information You Provide Directly

When you contact us or use our services, you may provide us with personal information including your name, email address, postal address, date of birth, employment details, and financial information relevant to your pension planning needs. This information is necessary for us to provide you with appropriate advice and services.

Information We Collect Automatically

When you visit our website, we automatically collect certain information about your device and how you interact with our site. This includes your IP address, browser type, operating system, referring URLs, pages viewed, and the dates and times of your visits. We use cookies and similar technologies to collect this information.

Information from Third Parties

In some circumstances, we may receive information about you from third parties, such as pension providers, financial institutions, or professional advisers, where you have authorised them to share information with us for the purpose of providing our services.

How We Use Your Information

We process your personal information for the following purposes:

Providing Our Services

We use your information to deliver pension planning advice, conduct reviews of your existing arrangements, prepare recommendations, and implement agreed strategies. This processing is necessary for the performance of our contract with you and to comply with our regulatory obligations as an FCA-authorised firm.

Communication

We use your contact information to respond to your enquiries, schedule consultations, provide updates on your pension planning, and send you important information about our services or changes to our terms.

Legal and Regulatory Compliance

As a regulated financial services firm, we are required by law to collect and retain certain information about our clients. We use your information to comply with anti-money laundering regulations, regulatory reporting requirements, and other legal obligations.

Improving Our Services

We analyse aggregated and anonymised data to understand how our website is used and to improve our services. This helps us identify areas where we can better serve our clients.

Legal Basis for Processing

We process your personal information on the following legal grounds:

• Contractual Necessity: Processing is necessary to provide the services you have requested and to fulfil our contractual obligations to you.
• Legal Obligation: We are required by law to process certain information to comply with financial services regulations, anti-money laundering requirements, and other legal duties.
• Legitimate Interests: We process some information based on our legitimate business interests, such as improving our services, protecting against fraud, and maintaining the security of our systems.
• Consent: In certain circumstances, such as sending marketing communications, we rely on your explicit consent, which you may withdraw at any time.

How We Share Your Information

We do not sell your personal information to third parties. We may share your information in the following circumstances:

Service Providers

We work with trusted third-party service providers who assist us in delivering our services, such as IT support, document storage, and professional indemnity insurance. These providers are contractually obligated to protect your information and may only use it for the purposes we specify.

Pension Providers and Financial Institutions

To implement your pension strategy, we may need to share relevant information with pension providers, investment platforms, or other financial institutions. We only share information that is necessary for these purposes and with your authorisation.

Legal Requirements

We may disclose your information if required to do so by law, regulation, court order, or by requests from law enforcement or regulatory authorities. This includes sharing information with the Financial Conduct Authority, HMRC, or other regulatory bodies.

Professional Advisers

We may share your information with our legal advisers, accountants, or auditors where necessary for the operation of our business or to comply with professional obligations.

How We Protect Your Information

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

• Secure storage of physical documents in locked, access-controlled facilities
• Encryption of electronic data both in transit and at rest
• Regular security assessments and updates to our IT systems
• Strict access controls limiting who within our organisation can view your information
• Employee training on data protection and confidentiality obligations
• Regular backups to prevent data loss

While we take these precautions seriously, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but are committed to protecting your information to the best of our ability.

How Long We Keep Your Information

We retain your personal information for as long as necessary to fulfil the purposes for which it was collected and to comply with our legal and regulatory obligations.

For clients with whom we have an active relationship, we retain your information for the duration of our engagement and for six years following the conclusion of our professional relationship. This retention period is in line with Financial Conduct Authority requirements and ensures we can respond to any future queries or complaints.

For enquiries that do not result in a client relationship, we typically retain your information for up to two years, after which it is securely deleted.

In some cases, we may be required to retain information for longer periods to comply with specific legal obligations, such as anti-money laundering record-keeping requirements.

Your Rights

Under data protection law, you have several rights regarding your personal information:

Right of Access

You have the right to request a copy of the personal information we hold about you. This is commonly known as a "subject access request". We will provide this information free of charge, typically within one month of your request.

Right to Rectification

If you believe any information we hold about you is inaccurate or incomplete, you have the right to request that we correct or complete it.

Right to Erasure

In certain circumstances, you may request that we delete your personal information. However, this right is not absolute—we may need to retain certain information to comply with legal obligations or establish, exercise, or defend legal claims.

Right to Restrict Processing

You may request that we restrict how we use your personal information in certain situations, such as while we verify the accuracy of information you have disputed.

Right to Data Portability

Where we process your information based on your consent or for the performance of a contract, you have the right to receive your data in a structured, commonly used format and to transmit it to another organisation.

Right to Object

You have the right to object to processing based on legitimate interests. You also have an absolute right to object to processing for direct marketing purposes.

Rights Related to Automated Decision Making

We do not use automated decision-making or profiling in our pension advisory services. All advice is provided by qualified human advisers.

Exercising Your Rights

To exercise any of these rights, please contact us using the details provided at the end of this policy. We may need to verify your identity before responding to your request to ensure we are providing information only to the person entitled to it.

If you are not satisfied with how we have handled your information or responded to your request, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection regulator. You can contact the ICO at ico.org.uk.

Cookies and Tracking Technologies

Our website uses cookies and similar technologies. For detailed information about the cookies we use and how to manage your preferences, please see our Cookies Policy.

Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. We encourage you to read the privacy policies of any third-party sites you visit.

Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make significant changes, we will notify you by posting a prominent notice on our website or, where appropriate, by contacting you directly. The "last updated" date at the top of this policy indicates when it was most recently revised.

Contact Us

If you have any questions about this privacy policy, how we handle your personal information, or if you wish to exercise any of your rights, please contact us:

dreamshade-pond Limited
47 Threadneedle Street
London
EC2R 8AU
United Kingdom

Email: [email protected]

We aim to respond to all privacy-related enquiries within five working days.