Privacy Policy

Last updated: September 2024

1. Introduction

Sly Treasury Ltd ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our financial planning services.

This policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are registered with the Information Commissioner's Office (ICO) and are authorised and regulated by the Financial Conduct Authority (FCA).

2. Information We Collect

Personal Information

We may collect the following types of personal information:

• Contact Information: Name, email address, telephone number, postal address
• Financial Information: Income, assets, liabilities, investment objectives, risk tolerance
• Identification Information: Date of birth, National Insurance number, passport/driving licence details
• Employment Information: Occupation, employer details, employment history
• Family Information: Marital status, dependents, beneficiary information
• Communication Records: Correspondence, meeting notes, phone call recordings

Technical Information

When you visit our website, we automatically collect:

• IP address and geographic location
• Browser type and version
• Operating system
• Pages visited and time spent on pages
• Referral source
• Device information

3. How We Use Your Information

We use your personal information for the following purposes:

Service Delivery

• Providing financial planning and advisory services
• Conducting suitability assessments
• Managing your investment portfolio
• Processing transactions
• Regular portfolio reviews and reporting

Legal and Regulatory Compliance

• Meeting FCA regulatory requirements
• Conducting know-your-customer (KYC) checks
• Anti-money laundering (AML) compliance
• Record keeping requirements
• Complaints handling

Communication

• Responding to enquiries
• Providing updates on your investments
• Sending regulatory notices
• Marketing communications (with consent)
• Newsletter subscriptions

4. Legal Basis for Processing

We process your personal data based on:

• Contract: To perform our financial advisory services
• Legal Obligation: To comply with FCA regulations and other legal requirements
• Legitimate Interest: To improve our services and manage our business
• Consent: For marketing communications and non-essential cookies

5. Information Sharing

We may share your information with:

Third-Party Service Providers

• Investment platforms and product providers
• Pension and insurance companies
• Mortgage lenders and brokers
• Professional indemnity insurers
• IT service providers and data processors

Regulatory Bodies

• Financial Conduct Authority (FCA)
• HM Revenue & Customs (HMRC)
• Financial Ombudsman Service
• Other regulatory authorities as required

Professional Advisers

• Solicitors and legal advisers
• Accountants and tax specialists
• Other financial professionals (with your consent)

6. Data Retention

We retain personal data for as long as necessary to:

• Provide ongoing services to you
• Meet regulatory requirements (minimum 6 years for FCA records)
• Handle any complaints or claims
• Comply with legal obligations

7. Your Rights

Under UK GDPR, you have the right to:

• Access: Request copies of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to legal requirements)
• Restriction: Limit how we process your data
• Portability: Receive your data in a structured format
• Object: Opt out of certain types of processing
• Withdraw Consent: Remove consent for marketing communications

To exercise these rights, contact us using the details below.

8. Cookies and Website Analytics

Our website uses cookies to:

• Ensure essential website functionality
• Remember your preferences
• Analyse website usage (with consent)
• Improve user experience

You can manage cookie preferences through our cookie banner or browser settings. For more information, see our Cookie Policy.

9. Data Security

We implement appropriate technical and organisational measures to protect your data:

• Secure servers and encrypted data transmission
• Access controls and staff training
• Regular security assessments
• Professional indemnity and cyber insurance
• Secure disposal of confidential information

10. International Transfers

We primarily process data within the UK. If we transfer data internationally, we ensure adequate protection through:

• Adequacy decisions by the UK government
• Standard contractual clauses
• Other approved transfer mechanisms

11. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of significant changes and post the updated policy on our website with a new "last updated" date.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

13. Complaints

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with: