Engage Financial Services Ltd
Privacy Policy
This privacy notice explains how Engage Financial Services Ltd uses any personal information we collect about you.
Who we are:
We are responsible for your personal information and are registered with the Information Commissioner’s Office (ICO). Our ICO registration number is ZA250084.
What information do we collect about you?
We collect information about you when you engage us for financial planning services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us, or when you submit a complaint to us.
Why do we need to collect and use your personal data?
We process your personal data where this is necessary to take steps at your request before entering into a contract with you and to perform our contract with you. We also process personal data where this is necessary to comply with our legal and regulatory obligations, including obligations relating to anti-money laundering, fraud prevention, record keeping and the provision of regulated financial services. In some circumstances we may process personal data where this is necessary for our legitimate interests, provided those interests are not overridden by your rights and interests.
Where we need to process special category personal data, such as health information, we will only do so where we have an appropriate lawful basis and condition under UK data protection law. This may include your explicit consent (i.e. via our Data Protection Agreement) where required, or another condition permitted by law where applicable.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us, to manage our relationship with you, to comply with our legal and regulatory obligations, and to handle any complaints or data subject rights requests you submit.
Who might we share your information with?
If you agree (by giving consent via our Data Protection Agreement), we may email you about other products or services that we think may be of interest to you. We won’t share your information for marketing purposes with other companies.
In order to deliver our services to you effectively, we may share your personal data with third parties where this is necessary. These may include professional advisers, compliance consultants, accountants, legal advisers, identity verification providers, IT and cloud service providers, document management providers, product providers, platform providers, discretionary investment managers and other parties involved in arranging, administering or servicing the products and services we recommend to you.
Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes. However, you should be aware that as a result of this, it will leave a ‘soft footprint’. This means that there will be no impact on an individual’s credit file and would not be seen by any company conducting a credit check on you. You must advise us if you do not wish this check to take place.
In the event that you submit a complaint to us, your personal data may be shared with our professional indemnity insurers, the Financial Ombudsman Service (FOS), and any third parties whose involvement is necessary to investigate the complaint. Such sharing will always be subject to appropriate contractual safeguards.
Technology and AI service providers
Some of our service providers, including certain technology and AI service providers, may process personal data on our behalf. Where AI tools or services are used, we ensure that:
they are subject to appropriate data processing agreements;
personal data is not used to train third-party AI models without an appropriate lawful basis; and
any automated processing with significant effects on you is subject to appropriate human oversight.
We do not use solely automated decision-making (including profiling) that produces legal effects or similarly significant effects on you, unless permitted by law and appropriate safeguards are in place. If we make a decision about you based solely on automated processing, you have the right to receive information about that decision, to request human intervention, to express your point of view, and to challenge the decision.
Some of our service providers may process personal data in the United Kingdom, the European Economic Area, or in other countries. Where we make a restricted transfer of personal data outside the United Kingdom, we will ensure that an appropriate transfer mechanism is in place, such as UK adequacy regulations, appropriate safeguards, or another lawful exception permitted by UK data protection law. You can contact us if you would like more information about any such safeguards.
How long do we keep hold of your information?
We will not keep your personal data for longer than is necessary for the purposes for which it was collected, including to meet our contractual, legal, regulatory, accounting and reporting obligations, and to establish, exercise or defend legal claims. We maintain retention schedules and review the personal data we hold so that it is kept accurate, up to date and only for as long as required.
As our services include advice on long-term investments, including pension and assurance-based products, we may need to retain relevant personal data for extended periods. We are also subject to FCA record-keeping requirements. Specific retention periods include:
Pension transfer, pension conversion, pension opt-out, and FSAVC suitability records: indefinitely, as required by the FCA;
Other investment and life policy records: 6 years from the end of our relationship;
Complaint records: a minimum of 3 years from receipt of the complaint (5 years for complaints relating to collective portfolio management services for a UCITS scheme), in accordance with DISP 1.9.1R; and
Records where no specific legal or regulatory obligation applies: a maximum of 10 years following the termination of our relationship.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above. For example, we may not be able to delete complaint records during the minimum FCA retention period. We will always explain the reason if we are unable to fulfil a deletion request.
How can I access the information you hold about me?
You have rights under UK data protection law, which may include the right to request access to the personal data we hold about you, to ask for inaccurate personal data to be corrected, to request erasure or restriction of processing in certain circumstances, and to object to processing where applicable. Where applicable, you may also have the right to data portability.
If you’d like to exercise any of these rights, please contact us using the details noted below. We will respond to your request within one month of receipt. We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
Marketing
We may send you information about our products and services, and those of other companies in our group, where we are permitted to do so under applicable law. Where consent is required for electronic marketing, we will ask for it (via our Data Protection Agreement) and keep a record of your preference in our back-office database. You can opt out of marketing communications at any time.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.
Other websites
Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
Complaints about how we have handled your personal data
If you are unhappy with how we have handled your personal data, please contact us using the details below and tell us that you wish to make a data protection complaint. This section covers data protection complaints specifically. If you have a complaint about the financial services we have provided, please refer to our separate Complaint Handling Procedures, available on request or at www.engagefs.co.uk.
On receipt of a data protection complaint, we will acknowledge your complaint within five working days of receiving it, take appropriate steps to investigate and respond within one month (extendable by a further two months for complex requests, in which case we will inform you), keep you informed of progress where appropriate, and let you know the outcome.
If you remain unhappy with the outcome, you also have the right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113 (local rate)
Changes to our privacy policy
We keep our privacy policy under regular review and we’ll inform you of any changes when they occur. This privacy policy was last updated on 17 June 2026.
How to contact us
Please contact us if you have any questions about our privacy policy or information we hold about you:
By email at hello@engagefs.co.uk
Or write to us at Engage Financial Services Ltd, 1345 High Road, London, N20 9HR