Client First (FS) LLP (hereafter known as “Client First”) is
dedicated to promoting the best unbiased and independent financial advice to
business owners and individuals across the
This Policy is subject to change from time to time so please review this Policy regularly.
1. Outbound marketing
1.1. Our outbound call centre targets businesses across the
- Type of Business
- Business Name
- Business Address and postcode
- Telephone Number
1.2. All our calls are screened against TPS and CTPS and all data we hold on you is stored on an encrypted database local to our head office at 52-54 Devonport Road, Plymouth PL3 4DF (i.e. we do not use any cloud based storage) and will only be used by us at the point of contact in relation to the promotion/provision of our service. Any physical paperwork (written or computer generated) is securely disposed of at our earliest convenience via a confidential shredding facility provided to us by The Pluss Organisation (https://www.pluss.org.uk/).
1.3. In the course of our correspondence, any data voluntarily provided by you in addition to that in point 1.1. (e.g. email address, age, mobile number or financial product details), signifies a consent to share this information with one of our FCA registered financial advisers, should our correspondence result in you agreeing to a meeting. If our service is not of interest to you, or if you already retain the services of a financial adviser, then we will delete any sensitive information you provide to us but reserve the right to retain any of the details listed in point 1.1. to prevent us retargeting you in the near future.
2. Sharing your data
2.1. Should our initial correspondence result in you agreeing to a meeting with one of our FCA registered financial advisers, you agree that we can share your information with the relevant adviser/organisation. These details will be fully disclosed to you upon agreement and your information will be transferred by email in the form of a password protected PDF which will only be accessible by the designated adviser and any relevant employees of Client First. For our own records, we will electronically store in an encrypted database any information relating to this until the earliest of the below:
a) six months after ceasing to work on behalf of the adviser in question.
b) no later than one week after you have expressly told us in writing to delete any information relating to you (see more under the section 3. Your Rights).
2.2. Whilst GDPR requires all businesses look after your personal information in a secure manner, Client First is not responsible for how your data is used and stored by any third party that you agree with us to share your data. For more information on how your data is managed following transfer to the relevant adviser/organisation, please refer to their privacy policies.
3. Your rights
3.1. Under GDPR, you have the right to request that we delete any information we hold on you and that we will do so within a reasonable timeframe (usually within one week). However, to ensure that our service levels are kept to the highest possible standard and to assist you with any ongoing matters relating to the service provided to you by us and/or our FCA registered financial advisers, we strongly suggest that you “opt in” to receive any future correspondence from us – this will usually be a verbal instruction in our initial telephone contact.
3.2. If at any point you no longer wish to hear from us, please notify us by emailing firstname.lastname@example.org. Please note that in the course of our ongoing marketing activity every attempt is made to deduplicate future data orders against our past clientbase. By instructing us to delete your details from our database this forms an agreement that we can retarget you, assuming your business fulfils a certain criteria and is not subsequently registered with either TPS or the CTPS. As our bought-in data is licensed on an annual basis the minimum period for retargeting is 12 months from the initial date of purchase.
3.3. If you decide that you no longer wish to hear from any third party that we share your information with, please refer to their policies on data storage and notify them directly.
Internet Privacy and Cookies Policy
4. Information That We Collect
4.1. In running and maintaining our website we may collect and process the following data about you:
4.2. All personal data provided to us by you following any visit to our website will be subject to the same treatment as our outbound marketing. See points 1.1. to 1.3. above
5.2. We may gather information about your general internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally; it is statistical data which does not identify any personal details whatsoever.
You can adjust the settings on your computer to decline any cookies if you wish. This can be done within the “settings” section of your computer. For more information please read the advice at AboutCookies.org.
6. Use of Your Information
6.1. We use the information that we collect from you to provide our services to you. In addition to this we may use the information for one or more of the following purposes:
* To provide information to you that you request from us relating to our services.
* To inform you of any changes to our website or services.
6.2. Should you choose to share any personal financial data with us, via either our contact form or over the telephone, we agree that we will not share this with any third parties without your consent. Please refer to point 2.1.-2.2. above.
7. Disclosing Your Information
* In the event that we sell any or all of our business.
* Where we are legally required by law to disclose your personal information.
* To further fraud protection and reduce the risk of fraud.
8. Third Party Links
9. Access to Information
In accordance with the GDPR you have the right to access any information that we hold relating to you. Please note that we reserve the right to charge a fee of £10 to cover costs incurred by us in providing you with the information.
10. Contacting Us
Please do not hesitate to contact us regarding any matter relating to this Privacy and Cookies Policy via email at email@example.com