What information we store or handle, and for what purpose
We act as an intermediary, not as an advisor or service provider. In order to facilitate introductions between clients and regulated FX counterparties, we may receive certain personal and business information. Contact information and records of meetings and decisions are retained by us on a limited basis for relationship management. KYC/compliance documentation is passed directly and securely to the broker, after which we do not keep a copy.
- Names, occupation and contact details
- Records of meetings and decisions
- KYC/compliance documentation:
- Proof of address
- Passport
- Financial data (including income and expenditure)
- Credit history and credit reference information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
- Your right to rectification– You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
- Your right to erasure– You have the right to ask us to delete your personal information. You can read more about this right here.
- Your right to restriction of processing– You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
- Your right to object to processing– You have the right to object to the processing of your personal data. You can read more about this right here.
- Your right to data portability– You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
- Your right to withdraw consent– When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
- Legitimate interests – we’re collecting or using your information because it benefits you, our Organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Our service depends on our ability to pass a client’s contact details to the relevant FX broker, without which we cannot provide the service. The introduction is a core part of our offering — it would not be possible to operate the business or meet the client’s request without sharing this data. The benefit to the individual or business is that they receive a direct introduction to the most suitable broker for their needs. This saves the client time and effort and improves their access to appropriate services. We may also pass on KYC or compliance documentation to the selected broker where required for onboarding or credit referencing. Additionally, we store limited contact details for potential clients in our CRM system as part of our sales process. We believe this use of data is fair, proportionate, and expected in the context of a B2B intermediary relationship.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
- Directly from you
- Publicly available sources
How long we keep information
| Data Type | Retention Period | Reason | Deletion Method |
| Client contact details (CRM) | 2 years after last contact | Standard B2B retention for service continuity | Manual deletion from HubSpot |
| KYC/credit documentation (for broker use) | Immediately after transfer to broker | We are not the data controller for this | Not stored — no retention |
| Potential client leads (CRM) | 12 months from last contact | Legitimate interest for sales follow-up | Deleted from HubSpot |
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Others we share personal information with
- Third parties:
- The foreign exchange brokers we introduce clients to are authorised and regulated by the relevant financial authority. A full list of our partner brokers is available upon request.
Sharing information outside the UK
Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Organisation name: HubSpot
Category of recipient: CRM Platform
Country the personal information is sent to: US or EU
How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113