Financial Freedom Capital Management LLP (“FFCM”) firmly believes that our clients are entitled to the very best service we can offer – and that includes the right to feel comfortable about the personal non-public information you share with us. We respect every individual’s right to privacy. We understand the importance you place on the privacy and security of information that personally identifies you or your account information.

The Securities and Exchange Commission has implemented Regulation S-P, which relates to the privacy of consumer financial information, and has established rules in response to Section 504 of the Gramm-Leach-Bliley Act. Regulation S-P and the Gramm-Leach-Bliley Act limit investment companies, broker-dealers, and registered investment advisers in their disclosure of consumers’ and customers’ nonpublic personal information. Regulation S-P also requires that financial institutions provide privacy notices in various instances and to adopt policies and procedures to protect the personal information of its customers. This statement describes our firm’s privacy policy and how we handle your personal information. This policy applies to former, current, and prospective customers.

This notice is intended to tell you where we obtain information about you, how we use that information and who has access to the information. This notice applies to and includes all subsidiaries, parent or sister companies, limited liability companies, partnerships, or other entities controlling, controlled by, or under common control with FFCM.

Why and How We Collect Personal Information

We collect personal data from you in a number of ways:

From our website we collect information:

  • you provide by filling in one of our online enquiry forms; and
  • by using cookies for security purposes, marketing and ad-tracking and to monitor the services you use and how you use them.

From our clients we collect information:

  • you provide via our account application process and throughout our relationship with you whether face-to-face, by phone, email or otherwise and
  • about you from third parties, for example whilst carrying out routine checks during our client on-boarding process and from intermediaries when entering into or administering your agreement with us.

What information do we collect about you?

We collect the following types of personal data about you:

  • your name, and contact information such as address, email address and telephone number;
  • your date of birth, national insurance number (or other tax identification number) and due diligence information;
  • technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • financial information, employment history, nationality and dependents; and
  • your marketing preferences.

Why do we collect this information from you?

We collect and use your personal data to provide our services and to ensure we meet our regulatory requirements. Your data may also be used for marketing purposes, so that we can inform you about our products and services.

On what basis do we use your personal data?

We may process your personal data because:

  • it is necessary for the performance of our contract with you;
  • we have obtained your consent to do so;
  • of regulatory and legal requirements that we are subject to;
  • of the need to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
  • for our legitimate business interests such as:
     monitoring and efficiently managing the performance and operation of our business;
        •   outsourcing of parts of our back office functions to third parties;
        •    contacting you after you request information to see if we can provide further assistance and information about events, economic commentary and keep you informed of other services which might be of interest to you.

How long do we keep this information?

If you are not a client of ours, we will keep your information for a year after we last heard from you. If you ask us to remove you from our marketing list, we may keep your personal details on an “opted-out” list in order to ensure that we do not market to you again.

If you are or have been our client, we keep your information for 15 years after closure of your account. Where required by law or regulation, we keep documents relating to pension transfers indefinitely and recordings of telephone conversations with you for 5 years after they took place.

Who do we share your information with?

In addition to sharing your personal data with other members of the FFCM group, we may also disclose your personal data:

  • to our IT providers and services providers in order to provide and maintain the provision of our services;
  • to our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access to the information to provide advice;
  • to fraud prevention agencies and other organisations to allow us to undertake the relevant checks;
  • to providers of investments or services we work alongside with, including providers of pensions, offshore bonds, onshore bonds, trusts, investment platforms, discretionary management services, custodians, loans, insurance products or other such products or services. We may also be required to share information with the auditors appointed by the providers of such products or services;
  • to the Financial Conduct Authority, the Information Commissioner’s Office, or any relevant regulatory authority where they are entitled to require disclosure;
  • if required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
  • to relevant authorities to investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
  • if tax regulations require us to collect information about tax residency, then in certain circumstances (including if we do not receive a valid self-certification from you), we may be obliged to share information about your account with the relevant tax, payments and customs authority, who may pass this on to tax authorities in other jurisdictions; or
  • in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets.

We will not lend or sell your information to third parties.

Your personal information may need to be shared with our service providers, which may involve transferring it to countries outside the United States. Where we do so, we will ensure that we do this in accordance with current data protection legislation by only transferring your data to jurisdictions such as the UK and the British Isles, of which they are a part of the EU’s GDPR legislation and regulation which is currently the strictest data privacy and confidentiality law in the world.

Marketing

If you agree, we may send you information about our products and services by email and those of other companies in our group which may be of interest to you. Where it is in our legitimate interests, we may send you information about our products and services by post. If you have consented to receive marketing, you may still opt out at a later date. We may also use your name and address to post to you invitations to events, or to introduce you to other FFCM products or services which may reasonably be considered to be of interest to you.


You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please email us at info@ffcmanagement.com or write to us using the information at the end of this notice.

Automated decision-making

We may use automated decision making in order to comply with our regulatory requirements in relation to KYC/AML checks or to evidence we are providing a suitable and appropriate service to you.

What are your data protection rights?

You have certain rights in respect of the data we hold relating to you.

  • The right to access - you are entitled to a copy of the information we hold about you in a portable format or otherwise, this is known as a Subject Access Request.
  • The right to request rectification - you can request we correct any information you believe is inaccurate or incomplete.
  • The right to erasure – you can ask us to delete your data under certain circumstances but we may be legally entitled to retain

  • it so will not be able to erase or modify the data.
  • The right to object and the right to restrict processing – you can object or request we restrict the processing of the information we hold about you, again under certain circumstances but we may be legally entitled to continue processing and/or may refuse your request.
  • The right to data portability – you can request we transfer the data we have collected on you to another organisation or directly to you in a reasonable format specified by you.


In order to exercise these rights or if you have any concerns about our use of your personal information, please contact the Data Protection Officer using the information at the end of this notice. You can also contact the ICO in its capacity as our supervisory body.


We will endeavour to keep your information accurate, however, if at any time after giving us this information it becomes out of date, then we ask you to notify us directly and we shall remove or amend the information within a reasonable time frame and in accordance with legislative requirements.

Other websites

Our website contains links to other websites. This privacy notice only applies to our website. When you use a link to another website you should read the privacy policy of that site.

Changes to our Privacy Notice

We keep our privacy notice under regular review. This privacy notice was last updated in December 2019. We reserve the right to update this privacy notice at any time and we will advise you when we make any substantial update to it.