This privacy policy sets out how Pinson Brown financial coaching uses and protects your personal data.

1. Important information and who we are

Privacy policy

This privacy policy gives you information about how Pinson Brown Financial Coaching collects and uses your personal data through your use of this website, including any data you may provide when you register with us and we provide a service. 

This website and service is not intended for children and we do not knowingly collect data relating to children. 

Controller

Pinson Brown Financial Coaching is the controller and responsible for your personal data (collectively referred to as “COMPANY", "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the information set out in the Contact details section.  

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

•  Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes details of your savings, investments, pensions and debts, as provided by you in writing or orally during our meetings, and within a Financial Life Plan in the third-party Voyant financial planning software, where services provided by us require this.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
• Usage Data includes information about how you interact with and use our website, products and services. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering. 

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering. 

3. How is your personal data collected? 

We use different methods to collect data from and about you including through:  

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

○ apply for our products or services;

○ provide information for the purpose of fulfilling the service;

○ subscribe to our service or publications; or

○ give us feedback or contact us.

•  Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

● Technical Data is collected from the following parties:

○ analytics providers such as Google based outside the UK;

○ advertising networks; and

○ search information providers. 

• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
• Identity and Contact Data is collected from data brokers or aggregators. 

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases: 

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you. 
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter. 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.  

To view this table, please view the pdf version of our privacy policy. Found at the bottom of every page on our website.

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing. 

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications. 

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us support@pinsonbrown.com. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes. 

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

•  Internal Third Parties.
• External Third Parties such as our software provider ‘Cashcalc’.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 6. International transfers

Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

Under data protection laws, we can only transfer your personal data to a country outside the UK where:

• in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR.
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you;
• a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on Changes to this privacy policy below.

 8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.  

How your data is stored

Your personal information is stored on third party platforms; Google Drive which is highly secure and encrypted in-transit and at-rest, CashCalc which uses bank-level encryption (AES-256), which means when we can securely communicate and share information with each other, it is encrypted and confidential between both us and you. Both of these data storage providers offer 2-factor authentication.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of Marketing for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data's accuracy; 
• Where our use of the data is unlawful but you do not want us to erase it; 
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us see Contact details.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data, or you want to exercise your privacy rights, please contact us by email via the following address: support@pinsonbrown.com. 

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 5th April 2025. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.  

14. Your Consent

While we rely on various lawful bases to process your personal data, as detailed in Section 4 ('How we use your personal data'), there may be circumstances where we specifically require your consent.

• When We Will Ask for Consent: We will ask for your explicit consent before:
  
  
  • Sending you direct marketing communications via email or SMS, unless otherwise permitted by law (you can opt-out of marketing at any time, as explained in Section 6).
  • Sharing your personal data with third parties for their own direct marketing purposes.
  • Placing non-essential cookies or similar tracking technologies on your device (our Cookie Policy provides more detail on this and how you can manage your preferences).
  • Processing any special categories of personal data, where consent is the appropriate lawful basis.
  • Using your data for any new purpose that is incompatible with the purposes we originally collected it for, where consent is the required lawful basis.
• How We Obtain Consent: Where we require your consent, we will provide you with clear information about the specific activity we are seeking consent for. Consent will require a positive opt-in action from you (for example, ticking an unticked checkbox or clicking an 'accept' button). We will not assume consent from your silence, pre-ticked boxes, or general use of our website or services.
  
   
• Withdrawing Your Consent: You have the right to withdraw your consent at any time for any processing activities where we rely on consent as the lawful basis. Withdrawing consent is straightforward and can typically be done by:
  
  
  • Using the 'unsubscribe' link in any marketing email we send you.
  • Adjusting your preferences via our cookie management tool (if applicable).
  • Contacting us directly using the details provided in Section 10 ('Contact details').

Please note that withdrawing consent will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw consent, we may not be able to provide certain products or services  to you. We will advise you if this is the case at the time you withdraw your consent.