Privacy Approval
MOLYNEUX ASSOCIATES PRIVACY POLICY
Molyneux Associates Ltd — Envoy House, 61 Longbridge Road, Plymouth, England, PL68LU — 5075008 — FCA Reference Number: 624563 Last updated: 01/07/2026
1.Introduction
Molyneux Associates Ltd (“we”, “us”, “our”) is committed to protecting and respecting your privacy. We are the data controller for the personal information we process about you. This Privacy Policy explains how we collect, use, store and protect your personal information in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Data (Use and Access) Act 2025, and any successor legislation.
2. Who This Policy Applies To
This policy applies to personal information we process relating to: ● Clients and prospective clients ● Website visitors ● Introducers and professional connections ● Product providers and third parties ● Suppliers and service providers
3. Personal Information We Collect
Identity and contact data ● Name ● Address ● Email address ● Telephone number ● Date of birth ● National Insurance number Financial and advisory data ● Income and expenditure ● Assets and liabilities ● Pension and investment details ● Financial objectives and risk profile ● Bank and account information (where relevant) Sensitive personal data (special category data) In limited circumstances, we may collect: ● Health information ● Lifestyle and medical history ● Ethnic origin (where required for product applications) ● Criminal convictions and offences data (where relevant and permitted) Technical data (website use) ● IP address ● Browser type and device information ● Cookies and usage data
4.How We Collect Your Information
We may collect personal information when you: ● Contact us via website forms, email or telephone ● Engage us for financial advice or services ● Complete fact-finding or application forms ● Use our website ● Interact with us through third-party providers or introducers We may also receive information from: ● Product providers and financial institutions ● Identity verification and fraud prevention agencies ● Credit reference agencies (where applicable) ● Employers or pension schemes (where relevant)
5. How We Use Your Personal Information
We use your personal information to: ● Provide financial planning and advice services ● Arrange financial products and investments ● Verify identity and prevent fraud ● Assess suitability and financial objectives ● Administer ongoing client relationships ● Maintain regulatory and legal compliance ● Respond to enquiries, complaints or disputes ● Improve our services and operations ● Send marketing communications (where permitted) We do not use your personal information for any form of automated decision-making, including profiling, which produces legal or similarly significant effects on you. If this changes, we will notify you and explain the safeguards and rights that apply to that processing.
6. Lawful Basis for Processing
We process your personal information under the following lawful bases: ● Contract – to provide agreed financial services ● Legal obligation – to comply with FCA, tax and regulatory requirements ● Legitimate interests – for business operations, client servicing and improvement of services ● Consent – where required for marketing or special category data processing Where we rely on legitimate interests, we carry out an assessment to balance our interests against your rights and freedoms; details of this assessment are available on request from our Privacy Officer. Where we process special category data, we do so under your explicit consent or where otherwise permitted by law.
7. Sharing Your Personal Information
We may share your personal information with: Financial service providers ● Investment platforms ● Pension providers ● Insurance companies ● Banks and lenders ● Fund managers and discretionary investment managers Service providers and processors ● CRM systems and client management software ● Financial planning and research tools ● Cashflow modelling and risk profiling software ● Compliance consultants and paraplanning services ● IT service providers and cloud hosting providers ● Secure document storage providers ● Electronic identity verification providers Regulatory and legal bodies ● Financial Conduct Authority (FCA) ● Financial Ombudsman Service (FOS) ● Financial Services Compensation Scheme (FSCS) ● HM Revenue & Customs (HMRC) ● Law enforcement agencies and courts We only share information where necessary and where appropriate safeguards are in place.
8. International Data Transfers
Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place, such as: ● UK International Data Transfer Agreements (IDTAs) ● UK adequacy regulations ● Standard contractual clauses or equivalent safeguards
9. Data Retention
We retain personal information only for as long as necessary for the purposes for which it was collected, including legal, regulatory and accounting requirements. Typically: ● Client records are retained for a minimum of 7 years after the end of the client relationship, or longer where required by regulation or legal obligation ● Website enquiries that do not proceed to a client relationship are retained for no longer than 24 months from the date of last contact, before being securely deleted or anonymised ● Marketing data is retained until consent is withdrawn or no longer valid ● Supplier data is retained for the duration of our contractual relationship, plus 7 years thereafter for statutory and accounting purposes
10. Data Security
We take appropriate technical and organisational measures to protect personal data against: ● Loss ● Misuse ● Unauthorised access ● Disclosure ● Alteration or destruction Access to personal data is limited to authorised personnel and service providers who require access to perform their duties.
11. Cookies and Website Usage
Our website uses cookies and similar technologies to: ● Improve user experience ● Analyse website usage ● Ensure website functionality You can control cookies through your browser settings. A separate Cookie Policy may be provided where required.
12. Marketing Communications
We may contact you about products and services that may be relevant to your financial needs where you have consented to receive such communications. You may opt out at any time by: ● Clicking unsubscribe links in emails ● Contacting us directly ● Emailing our Privacy Officer
13. Your Rights
Under UK data protection law, you have the right to: ● Access your personal data ● Request correction of inaccurate data ● Request deletion of your data (where applicable) ● Restrict processing ● Object to processing ● Request data portability ● Withdraw consent where applicable To exercise any of these rights, please contact our Privacy Officer using the details in section 16.
14. Complaints
If you are unhappy with how we handle your personal data, you have the right to complain to us directly in the first instance. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113.
15. Changes To This Policy
We may update this Privacy Policy from time to time. The latest version, with its date of publication, will always be available on our website. Where appropriate, we will notify you of material changes.
16. Contact Details
If you have any questions about this Privacy Policy or how we handle your data, please contact: Privacy Officer – Thomas Molyneux - Molyneux Associates Ltd Email: privacy@molyneux-associates.co.uk Telephone: 01752 567033 Post: Envoy House, 61 Longbridge Road, Plymouth, PL6 8LU
Covering: Plymouth, Torbay, Exeter, Devon, Cornwall and the South West Peninsula
Molyneux Associates Ltd is authorised and regulated by the Financial Conduct Authority.
and is entered on the Financial Services register (https://www.fca.org.uk/consumers/fca-firm-checker/search) under "Molyneux Associates Ltd" (reference 624563).
Further information about the Financial Ombudsman Service (FOS) is available from their website (https://www.financial-ombusdman.co.uk)