WEBSITE PRIVACY NOTICE

Privacy Notice

Effective Date: 15 September 2026
Last Reviewed: 15 September 2026
Next Review Date: 15 September 2027
Version: 3.0

Introduction

Adviser Services Holdings Limited and its group companies are committed to protecting and respecting your privacy.

This Privacy Notice explains how we collect, use, share, retain and protect your personal information when you:

• Visit our websites;
• Use our online portals and services;
• Contact us by telephone, email, post, website forms or other communications channels;
• Apply to join our networks or use our services;
• Receive communications from us.

Please read this Privacy Notice carefully together with any other privacy notice we provide when collecting personal information for specific purposes.

1. Who We Are

The Adviser Services Holdings Group comprises:

• Lyncombe Consultants Limited
• Sense Network Limited
• Adviser Services Holdings Limited

The company with which you interact will normally be the controller of your personal information.

In certain circumstances Adviser Services Holdings Limited and the relevant operating company may jointly determine how and why your personal information is processed. In these cases they may act as Joint Controllers.

Contact Details

Data Privacy Lead

Email: dataprivacy@adviserservices.co.uk

Telephone: 01565 658840

Postal Address:

Adviser Services Holdings Limited
Brookdale Centre
Manchester Road
Knutsford
WA16 0SR

2. Personal Information We Collect

Depending on how you interact with us, we may collect the following categories of personal information.

Identity Data

• Name
• Title
• Date of birth
• Username or platform identifier

Contact Data

• Postal address
• Email address
• Telephone number

Adviser and Professional Data

• FCA registration information
• Business details
• Network membership details
• Professional qualifications

Financial Data

• Bank account details
• Commission and payment information
• Billing information

Technical Data

• IP address
• Device information
• Browser type and version
• Operating system
• Login information
• Website usage analytics

Usage Data

• Website activity
• Portal activity
• Feature usage
• Session information

Marketing Preferences

• Marketing choices
• Communication preferences
• Consent records

3. Special Category Data

We do not intentionally collect special category personal information through our websites.

However, if you voluntarily provide information relating to health, vulnerabilities, or other special category data, we will process that information only where permitted by applicable law.

4. How We Collect Personal Information

We collect information:

Directly From You

When you:

• Complete forms
• Register with us
• Contact us
• Request information
• Sign agreements
• Submit enquiries

Automatically

When using our websites and portals via:

• Cookies
• Analytics tools
• Website logs
• Similar technologies

From Third Parties

Including:

• FCA registers
• Professional bodies
• Service providers
• Publicly available sources
• Identity verification providers
• Analytics providers

5. How We Use Your Personal Information

We only use personal information where we have a lawful basis to do so.

Contract

To:

• Register advisers
• Provide services
• Manage accounts
• Process payments
• Support network activities

Legal Obligations

To:

• Meet regulatory requirements
• Comply with FCA obligations
• Prevent financial crime
• Meet tax and reporting obligations

Legitimate Interests

To:

• Manage and improve our business
• Protect our systems
• Prevent fraud
• Respond to enquiries
• Improve website functionality
• Analyse service performance
• Develop services

Where we rely on legitimate interests, we ensure that your rights and interests are appropriately balanced.  

Consent

Where required, we will rely on your consent for:

• Certain cookies and analytics technologies
• Certain direct marketing communications

You may withdraw consent at any time.

6. Marketing Communications

We may send you information regarding products, services, events, regulatory developments, and business updates.

You can unsubscribe at any time by:

• Clicking the unsubscribe link in marketing emails;
• Updating your preferences through our Privacy Choices Centre; or
• Contacting us directly.

We do not share personal information with third parties for their own marketing purposes unless you have provided explicit consent.

7. Cookies and Similar Technologies

We use cookies and similar technologies to:

• Operate our websites;
• Improve performance;
• Analyse visitor activity;
• Remember your preferences.

Where required by law, we will obtain your consent before placing non-essential cookies on your device.

You may manage cookie preferences at any time via our Privacy Choices Centre.

Further information can be found in our Cookie Policy.

8. Automated Decision-Making and Profiling

We do not make decisions based solely on automated processing that produce legal effects or similarly significant effects on individuals.

If this changes, we will update this notice and inform affected individuals where required.

9. Sharing Your Personal Information

We may share personal information with:

Group Companies

Within the Adviser Services Holdings Group.

Service Providers

Including:

• Microsoft 365
• CRM providers
• Cloud hosting providers
• Managed IT providers
• Security monitoring providers
• Professional advisers

Regulators and Authorities

Including:

• Financial Conduct Authority
• HM Revenue & Customs
• Information Commissioner's Office
• Law enforcement agencies where legally required

Business Transactions

If part of our business is sold, transferred, restructured or merged.

All third parties are required to process personal information securely and only for authorised purposes.

10. International Transfers

Some service providers operate outside the United Kingdom.

Where personal information is transferred internationally, we ensure appropriate safeguards are implemented, including:

• UK Adequacy Regulations;
• UK International Data Transfer Agreements (IDTA);
• UK Addendum to the EU Standard Contractual Clauses;
• Additional technical and organisational security measures.

Further information is available upon request.

11. Data Security

We maintain appropriate technical and organisational measures to protect personal information.

These include:

• Access controls;
• Encryption;
• Security monitoring;
• Staff training;
• Incident management procedures;
• Supplier security assessments.

12. Data Retention

We retain personal information only for as long as reasonably necessary.

Typical retention periods include:

Where legal claims, investigations or regulatory obligations require, information may be retained for longer.

When retention periods expire, information is securely deleted or anonymised.

13. Your Rights

You have the right to:

• Access your personal information;
• Correct inaccurate information;
• Request deletion;
• Restrict processing;
• Object to processing;
• Receive a copy of your data in portable format;
• Withdraw consent where processing relies upon consent;
• Object to direct marketing.

You can exercise any of these rights by contacting:

dataprivacy@adviserservices.co.uk

We will usually respond within one month.

14. Complaints

If you have concerns about how we handle your personal information, please contact us first.

We will:

• Acknowledge complaints promptly;
• Investigate concerns fairly;
• Keep you updated regarding progress;
• Communicate the outcome of our investigation.

You also have the right to complain to the Information Commissioner's Office (ICO):

www.ico.org.uk

Telephone: 0303 123 1113

15. Changes to This Privacy Notice

We may update this Privacy Notice from time to time.

The most current version will always be published on our websites along with the review date and version number.