Privacy Policy 

Data Controller

The data controller responsible for this website is Pilgrim Wealth Management Ltd, of
67a High Street, Walton on Thames, Surrey, KT12 1DJ.

If you have any questions regarding this policy or your personal data, please contact us using the details published on our website.

This website may contain links to third-party websites. Those websites operate under their own privacy policies and act as separate data controllers. This privacy policy applies solely to this website.

Collected Personal Data

We may collect and process the following categories of personal data:

Identification and Contact Information

Name

Date of birth

Postal address

Email address

Telephone number

Financial Information

Information relating to pensions, investments, protection policies and financial objectives

Details of financial circumstances where voluntarily submitted via our contact forms

Technical Data

IP address

Browser type and version

Device information

Website usage data collected through cookies and analytics tools

Where we provide regulated financial advice, we may also process special category data, including information relating to health or medical history (for insurance underwriting purposes), where necessary and with appropriate safeguards.

Purpose of Collecting Data

We collect and process personal data in order to:

Respond to enquiries and provide requested information

Assess suitability and provide regulated financial advice

Arrange, administer and service financial products

Comply with our legal and regulatory obligations, including those imposed by the Financial Conduct Authority (FCA)

Maintain appropriate client and business records

Provide ongoing service arrangements where agreed

Improve our website and user experience

Send relevant communications where consent has been provided

Lawful Basis for Processing

We rely on the following lawful bases under UK GDPR:

Performance of a contract (where we provide advice or services)

Compliance with a legal obligation (including FCA regulatory requirements)

Legitimate interests (such as maintaining appropriate business records and ensuring service quality)

Explicit consent (for marketing communications or special category data where required)

Cookies and Google Analytics

Our website uses cookies to enhance user experience and to analyse website traffic.

We use Google Analytics to collect statistical data about how visitors use our website. This may include information such as IP address, pages visited, time spent on the website and referral sources. Where possible, IP anonymisation is enabled.

This information is used solely to improve website performance and user experience.

You may control or disable cookies through your browser settings. Where required, you will be given the option to accept or decline non-essential cookies.

Third-Party Portals

Our website may contain links to third-party platforms, including client portals hosted by True Potential LLP.

When accessing third-party websites or portals, their own privacy policies and data processing terms will apply. We encourage you to review their privacy policy before submitting personal data.

Data Sharing

We may share personal data with:

Product providers and investment platforms

Insurance companies

Compliance consultants

Professional advisers

IT and cloud service providers

We only share information that is necessary to deliver our services or meet regulatory obligations.

Data Retention

We retain client records in line with regulatory requirements, which may extend beyond the duration of our relationship.

Financial advice records are typically retained for a minimum of five years. In certain circumstances, including pension transfer advice, records may be retained for longer or indefinitely in accordance with FCA requirements.

Call Recordings and Online Meetings

Voicemail messages left on our office telephone system are recorded and retained for administrative purposes.

Meetings conducted via video conferencing platforms may be recorded or transcribed where agreed in advance. Participants will be notified where recording takes place.

We may retain notes and records of meetings where necessary to evidence advice and comply with regulatory obligations.

Your Rights

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

Request access to your personal data

Request correction of inaccurate data

Request erasure where legally permitted

Restrict processing

Request data portability

Lodge a complaint with the Information Commissioner’s Office (ICO)

Further information about your rights can be obtained from www.ico.org.uk.

Marketing Communications

We will only send marketing communications where you have provided consent. You may withdraw your consent at any time.

Regulatory Status

Pilgrim Wealth Management Ltd is authorised and regulated by the Financial Conduct Authority (FCA).
You can find us on the FCA Register under reference number 784239.