Customer Privacy Notice

General Data

Why should you read this document?

During the course of dealing with us, we will ask you to provide us with detailed personal information (Your Personal Data), so we can analyse your current and future financial needs. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulation (GDPR). We take your privacy very seriously and you can find our more here about your privacy rights and how we gather, use and share your personal information.

What do we mean by “Your Personal Data”?

Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth or National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation.

In the context of providing you with assistance in relation to your Investment, Pension or Annuity, Insurance and/or Wealth Protection requirements, Your Personal Data may include:

  • Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
  • Current and employment history and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits)
  • Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
  • Any pre-existing investment/pension/annuity/mortgage/finance/insurance and/or wealth protection products and the terms and conditions relating to these

Who we are

Holborn Assets Limited of Suite 5, Chester House, 79 Dane Road, Sale, Cheshire, M33 7BP acts as controller for the personal data you provide to us.

The basis upon which our Firm will deal with Your Personal Data

When we speak with you about your investment/pension/annuity/mortgage/finance/insurance and/or wealth protection requirements, we do so on the basis that both parties are entering into a contract for the supply of services.

In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data, provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.

On occasion, we will use Your Personal data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to investments/pensions/annuities/mortgages/finance/ insurances/wealth protection. You will provide information to us verbally and in writing, including email and post.

We may also obtain some information from a professional adviser if they have referred you to us, or from other third parties, for example, credit checks, information from your employer, information from your investment/pension/annuity/mortgage/insurance providers (where you have provided authority to do so), and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status, we will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

What happens to Your Personal Data when it is disclosed to us?

In the course of handling Your Personal Data, we will:

  • Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants of our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service
  • Submit Your Personal Data to Investment, Pension & Annuity Product Providers/Mortgage Lenders/Commercial Lenders, Wealth Protection Providers and/or Insurance Product providers, both in paper form and on-line via a secure The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
  • Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investment/pension/annuity/mortgage/finance/wealth protection product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware

Sharing Your Personal Data

From time to time your Personal Data will be shared with:

  • Investment/pension/annuity providers/mortgage lenders/finance lenders, insurance and wealth protection providers
  • Any professional adviser that may have referred you to us
  • Third parties and consultants who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as These third parties and consultants will include but may not be limited to, our Compliance Advisers, Back Office System Provider, IT specialists, Third Party Software Providers, Product specialists, Estate Agents and providers of legal services such as Solicitors or Will Planners (in each case where we believe this to be required due to your particular circumstances)

In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice,

i.e. to progress your investment/pension/annuity/mortgage/finance and/or insurance enquiry and to provide you with our professional services.

Sometimes we share personal information with third parties in countries outside the UK and/or the EU.

Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

Security and retention of Your Personal Data

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information or are required to retain it by relevant regulations, we will retain records indefinitely.

Your rights in relation to Your Personal Data

In relation to the Personal Data we hold about you, you have the following rights:

  • Right to withdraw consent: Where you have given us your consent to use personal information, you can withdraw your consent at any
  • Access to your personal information: You can request access to a copy of your personal information. We will not normally charge for providing this information to
  • Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a commonly used electronic
  • Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
  • Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it. Note that we might be required by regulations to retain your information even if you want it to be
  • Right to object: You can object to our processing of your personal
  • Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of

How to make contact with our Firm in relation to the use of Your Personal Data

If you have any questions or comments about this document or wish to make contact in order to exercise any of your rights set out within it please contact: Christopher Wicks on 0161 969 2646 or by email on [email protected] Alternatively, you can write to us at the address shown above.

If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Pension Transfer Experts is a trading style of Holborn Assets Ltd which is authorised and regulated by the Financial Conduct Authority. Holborn Assets Ltd is entered on the Financial Services Register under firm reference 648817.  Holborn Assets Ltd is registered in England and Wales No. 09046342.  Registered address: Suite 5, Chester House 79 Dane Road, Sale Cheshire M33 7BP.

This website and the information contained within it is directed at individuals resident in the UK.

Pension Transfer Experts logo

Suite 5, Chester House, 79 Dane Road, Cheshire, M33 7BP
0161 969 2646
[email protected]

If you wish to register a complaint, please write to [email protected] or telephone 0161 969 2646.

A summary of our internal complaints handling procedures for the reasonable and prompt handling of complaints is available on request and if you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service at or by contacting them on 0800 023 4 567.

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