Our advisors and True Potential (or which our advisors are respresenting) is a wealth management company that supports its clients by providing them with sound financial advice and suitable products and services to sustain their financial security.
At True Potential, we take the privacy and security of your personal data very seriously. In this notice, “we,” “us” or “our” means the True Potential Group which is made up of the following legal entities:
We act as a data controller for some processing activities, for example, we decide how and why your personal data is collected and handled on our investments and wealth management platforms but we are also a data processor for other activities such as acting on the instruction of Directly Authorised firms who use our digital platform to manage their clients.
All our entities are registered with the Information Commissioner’s Office (ICO) for various processing activities covered under Article 30 of the UK-GDPR.
Below are types of personal data we may hold about you depending on how it was collected.
You may give us your personal data when you engage with us by phone, email, in writing or otherwise. Here are some examples of when your personal data will be collected and then held by us. When you:
The information you give us may include your name, address, email address and other contact information, financial information, (including existing investments, funds held with banks and other financial institutions), information regarding financial debts, (mortgages, loans, credit cards) and debit card information.
When you visit our sites or use our services, we may automatically collect the following information.
As well as sharing information between entities within our Group we may also receive information about you from third party service providers. The type of third parties we work with include:
This information could be used as part of the service we provide to you, or as part of our regulatory or legal obligations. We may combine this information with information you give to us and information we collect about you.
Keeping your personal data safe is very important to us so we will take all steps necessary to ensure that your personal data is treated securely and in accordance with this Privacy Notice and applicable data protection legislation.
To help protect your personal data and minimise the risk of it being intercepted by unauthorised third parties, our secure servers employ Secure Socket Layer v3 (SSL) or Transport Layer Security v1 (TLS) encryption when you submit information to us through our sites. This security is signified by the “https” and the padlock on the URL bar. Some older browsers do not allow the use of current SSL technology and we, therefore, recommend that you use an up-to-date browser.
Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access.
We have considered the use of your personal data and have justified it based on one of the six options available under data protection law. If we use any special category or sensitive personal data, we will invoke an additional condition under Article 9 of the UK-GDPR or Schedule 1 of the Data Protection Act 2018. See below on what we use your personal data for and the basis upon which we justify it.
This activity does not involve sending direct marketing communications (such as emails or SMS messages) to you using this data. Personal data is processed using privacy-protective techniques, including hashing prior to matching, and we do not receive information about individuals identified through these audiences
Legitimate interest
Adviser contract administration and deferred payment reconciliation
Former financial advisers, where necessary to administer adviser agreements, including the reconciliation of deferred payments following the transfer of client relationships
Legitimate interest
In some circumstances, we use biometric verification as part of our identity verification and financial crime controls. This involves comparing a selfie image against a government‑issued identity document to help confirm that the person accessing an account is genuinely present and that their identity is not being misused. We process biometric data for the purpose of the prevention and detection of crime, including impersonation and identity fraud. The data is subject to strict technical and organisational security controls, is used solely for identity‑verification and financial crime purposes not used for any other purpose, and is not retained for longer than necessary. Our identity‑verification supplier does not retain biometric images once verification has been completed.
Whilst we may share the personal data we hold about you with entities within the True Potential Group, we may also share your personal data with the following types of third parties to enable us to better understand your needs and run your accounts efficiently and in line with your expectations.
Partners, suppliers, and sub-contractors including:
Former financial advisers including:
Governmental or judicial bodies or agencies including:
Fraud and anti-money laundering prevention agencies, other companies, and organisations to prevent or detect financial and other crime including:
Advertisers including:
Introducers including:
Other third parties including:
We may also share your personal information with third parties if the make-up of the True Potential Group changes in the future. For example:
We do all we can to keep your personal data inside the UK or only to transfer i.e. send, store or allow access to your personal data to a country that has been deemed as having a similar level of protection around personal data like the UK as deemed by the UK Government.
If we do need to transfer your personal data beyond these countries, we will make sure that it is protected as if it were in the UK by undertaking a Transfer Risk Assessment (TRA) and using an appropriate safeguard such as:
Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. We will only ever support links to reputable companies who maintain the highest standards of data security in line with the UK -GDPR.
If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or how such websites collect and use your personal data. Please check these policies before you submit any personal data to these websites.
Our sites may include functionality to enable sharing via third party social media applications, such as the Facebook Share button and X widget. These social media applications may collect and use information regarding your use of our sites (see details on cookies).
Any personal data that you provide via such social media applications may be collected and used by that social media application and such interactions are governed by the privacy notices of the companies that provide the application. In the majority of cases, we do not have control over, or responsibility for, those companies or their use of your personal data.
Our sites use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our sites and allows us to improve our sites.
When we send you an email, we may track whether you have opened that email and whether you have clicked any links it may contain. This helps us measure the performance of our email campaigns. We do this by including single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you opened an email, your IP address, your browser or email client type, and other similar details.
Cookies are used on almost every website. They are small text files that are saved on your computer to help the site perform a number of functions. Here is why we use them:
SecurityTo provide securely our services so you can access your account, place a deal, or open a new accountEase of useTo remember your login information to help you access your account easily if you request this. Please do not ask us to remember your login information if you are on a public computerMonitor visitor numbers and activityTo monitor the number of people using our website and collectively monitor their activities.Understand how people get to our siteTo see how you arrive at our site (e.g. search for ‘True Potential’ on a search engine, or click on an email we have sent)Understand more about the types of people visiting our siteTo gather a little technical information about you use our site, such as your geographic location (to city level) and the type of web browsers you are usingDeliver relevant contentTo display adverts on other websites to you if you have previously accessed the True Potential website.Tailor your experienceRemember your settings and preferences to make using the True Potential site easier.
We use several types of Cookies including:
We make use of both types of cookies to maximise the security of our services and to ensure you always get an optimal service from our site.
We do not use cookies to track your use of the internet after leaving our website, nor do we store any information about you in cookies that others could read and understand.
First and Third-Party Cookies refer to the website/service placing the cookie. First-party cookies are those set by us. Third-party cookies are cookies that are authorised by us but provided via one of our suppliers. In some limited cases, we may use our suppliers to manage some of these cookies for us, but we never allow any third party to use these cookies for their own purposes.
We use a system of classification for our cookies developed by the International Chamber of Commerce. This allows us to classify the different types of cookies that we use on our website to provide you with more information about why we use them.
Strictly necessary cookies are cookies that are essential to provide specific services you have requested from us. These help us to:
Performance cookies aim to improve our website by collecting information about how you use our website. These help us to:
Functionality cookies will typically be set because of an action you have taken on our website but may also be set in the delivery of other services. These helps us to:
Promotional cookies may also be used to limit the number of times you see a promotion as well as help measure the effectiveness of the promotion.
Analytical cookies, supplied by Google Inc, help us to analyse how users use this website. When you accept cookies, your consent preferences will be updated and the information generated by the cookie about your use of our site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our site, compiling reports on website activity for website operators like us and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. Google will use this information for the purpose of evaluating your use of our site, compiling reports on website activity for website operators like us, measuring the effectiveness of our advertising campaigns, displaying relevant advertisements to users who have previously visited our website and providing other services relating to website activity and internet usage.
You may refuse the use of our cookies by selecting the appropriate settings on your browser but please note that if you do this you may not be able to use the full functionality of our site. Most web browsers allow you to manage cookies via the browser settings. For example, you may choose to delete existing cookies, prevent your browser from accepting new cookies, have the browser notify you when you receive a new cookie or disable cookies altogether.
By using this website, you consent to the processing of data about you by us and Google in the manner and for the purposes set out above.
The UK-GDPR provides the following rights for individuals:
Wherever possible we have created systems and processes for you to exercise these rights as easily as possible. For example, we have privacy notices and consent statements to help keep you informed about how your personal data will be handled and protected throughout our digital and in-person client journeys. You can also change your personal data through our website, app, call centre or your adviser.
Should you need to:
Please contact us using the methods outlined in the ‘How to contact us about data protection matters’ section of this document
We do not carry out any auto-decision making process about you because there is a human involved in all our digital processes.
Wherever your personal data is created to make a profile, such as when you visit our website so that we can target you with adverts, we have implemented safeguards such as obtaining your consent or allowing you to exercise your data protection rights to object to, appeal against or alter the personal data we hold on you.
Where we rely on legitimate interests for marketing-related activities such as audience matching, you have the right to object to this processing. If you object, we will stop using your data for these purposes, including excluding you from future audience matching activities.
If we need to change the reasons for the handling of your personal data, we have systems in place to obtain expert advice from our Data Protection Officer (DPO) and consider the risks and controls we need to ensure that the handling remains transparent, secure and of good quality.
You can withdraw any consent you have given us for the processing of your personal data at any time. Please contact us on the details below if you want to do so. Please note that if you do withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.
We would always prefer you to give us the opportunity to see if we can handle your complaint in the first instance. You can contact us using the details below. However, you have the right to complain to the Information Commissioner’s Office (ICO) where you think we have not used your personal data in accordance with data protection law. Details of how to do this can be found on www.ico.org.uk.
If you have any queries regarding privacy issues, you can email us at dataprotection@tpllp.com, or write to us at:
True Potential LLP
Newburn House
Gateway West
Newburn Riverside
Newcastle Upon Tyne
United Kingdom
NE15 8NX
Alternatively, you can call us on 0191 500 9164.
We may need to collect personal information by law, or under the terms of a contract we have with you.
If you choose not to give us this personal data, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a product or service you have with us.
We reserve the right to revise or supplement this Privacy Notice from time to time. We will place updates on our sites, inform you of the updates and where appropriate we will give you reasonable notice of any changes.
