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Privacy Policy

Privacy Notice

Our Privacy Policy - your rights, your information and how we use it

Bromige Financial is committed to protecting your personal information.

Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us. We may need to make changes to our Privacy Policy; so please check our website for updates from time to time. If there are important changes, such as changes to where your personal data will be processed, we will contact you to let you know.

This version of our Privacy Policy was last updated 24th April 2018.

How to contact us

If you have any questions about our Privacy Policy or the information we collect or use about you, please contact;

Alex Colville - Data Protection Officer
Bromige Financial
3 Riverview Business Park
Station Road, Forest Row, East Sussex, RH18 5FS


Information we collect and use

Information about you that we collect and use includes:

information about who you are, e.g. your name, date of birth and contact details

information connected to products or services recommended by us, e.g. your bank account details

information about your contact with us, e.g. meetings, phone calls, emails, letters

information that is automatically collected, e.g. via cookies when you visit our website

information classified as ‘sensitive’ personal information, e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it is needed to provide you with products or services for which we are making recommendations or to comply with our legal obligations

information you may provide us about other people, e.g. joint applicants or beneficiaries for products

information on children, e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)

What are cookies?

A cookie is a small file – it’s saved onto your computer or other device when you visit our website.

Cookies store small pieces of information. For example - they will remember you have visited our website or performed a certain action.

We use cookies to help us improve your experience when you visit our website. For example, a cookie might store information so you do not have to keep entering it.

Cookies also let us know which pages of our website you visited; they help us develop and market products and services.

persistent cookies - these stay valid, and will work until their expiry date (unless you delete them before they expire)

session cookies - these expire when you close your web browser

When someone visits we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make and do not allow Google to make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

In particular, we use cookies to identify if visitors have Javascript enabled, as this functionality is used to improve the visual appearance of the site. We also use cookies in order to provide the necessary information for Google Analytics.

Where we collect your information

We may collect your personal information directly from you, from a variety of sources, including:

an application form for a product or service

telephone conversations with us

emails or letters you send to us

meetings with one of our financial advisers

participating in research surveys to help us understand you better and improve our service

online services, such as our website

We may also collect personal information on you from places such as business directories and other commercially or publicly available sources, e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.

What we collect and use your information for

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:

you have given us your permission [consent] to send you information about products and services recommended by ourselves and/or selected third parties we have chosen to work with which we believe may be of interest and benefit to you

it is necessary to provide the product or service recommended to you, e.g. if you wish to invest in a pension or savings product, we will require some personal information including your name, address, date of birth, bank account details

it is necessary for us to meet our legal or regulatory obligations, e.g. to tell you about changes to our terms and conditions or for the detection and prevention of fraud

it is in the legitimate interests of Bromige Financial, e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from recommended products or services; where we need to process your information to better understand you and your needs so we can send you more relevant communications about recommended products and services you have with us; where we use artificial intelligence or computer algorithms to improve the products and services offered to you

it is in the legitimate interests of a third party, e.g. sharing information with a product provider to enable an application for a product to be completed and accepted

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with recommended products or services.Who we may share your in

We may share your information with

We may share your information with with third parties for the reasons outlined in 'What we collect and use your information for.'

These third parties include:

companies with common directors, e.g. Bromige Services (UK) Limited

product providers, e.g. investment, protection, pension, mortgage, insurance providers

companies we have chosen to support us in securely maintaining your data electronically, e.g. Bluecoat Software, Autotask Workplace

companies we have chosen to support us in delivering compliant files, e.g. Millen Compliance Limited, Trust Paraplanning

companies we have chosen to support us in delivering professional advice, e.g. accountants, solicitors

our regulators and supervisory authority, e.g. Financial Conduct Authority (FCA), Information Commissioner’s Office for the UK (ICO)

law enforcement, credit and identity check agencies for the prevention and detection of crime

HM Revenue & Customs (HMRC) e.g. for prevention of tax avoidance

We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.

Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

How long we keep your information

We will keep your personal information only where it is necessary to provide you with recommended products or services while you are a client.

We may also keep your information after this period, but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.

Your individual rights

You have several rights in relation to how Bromige Financial uses your information. They are:

Right to be informed

You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with – we do this in our privacy notice.

Right of access

You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).

Right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

Right to request erasure

You can ask for your information to be deleted or removed if there is not a compelling reason for Bromige Financial to continue to have it.

Right to restrict processing

You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we do not use it in the future for those reasons you have restricted.

Right to data portability

You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were looking to move to another adviser.

Right to object

You can object to Bromige Financial processing your personal information where: it is based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our privacy notice, please write to Alex Colville - Data Protection Officer at Bromige Financial, 3 Riverview Business Park, Station Road, Forest Row, East Sussex RH18 5FS or email him at

We will do our utmost to make things right.

If you are still unhappy, you can complain to our supervisory authority at