We may also disclose your information with:
• HM Revenue & Customs, Financial Conduct Authority, Regulators and other authorities acting as
processors based in the United Kingdom who require reporting of processing activities in certain
circumstances.
• The Insolvency Service, who require processing activities in relation to Breathing Space applications.
• Accountants, Solicitors, Compliance Consultants and other like services acting as processors, based in
the United Kingdom who require reporting of processing activities in certain legal and compliance
circumstances.
• 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 notice.
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.

INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the United Kingdom (UK) or European Economic Area (EEA).

DATA SECURITY
We, endeavour to maintain the highest standard of data privacy and security to protect your personal details
and other information concerning your account. We want our customers to feel completely confident in using
our services, therefore we regularly review our processes and procedures to protect your personal information
from unauthorised access and use, accidental loss and/or destruction.
We have put in place appropriate security measures with our IT providers with restricted access permissions
and backup procedures to prevent your personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees,
agents, contractors and other third parties who have a business need to know. They will only process your
personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator within the required regulatory timescale of a breach where we are legally required to do
so

DATA RETENTION
HOW LONG WILL YOU HOLD MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
Details of retention periods for different aspects of your personal data are available and you can request from
us by Contacting us. By law, we have to keep certain information about our customers, and this data will be
held solely and securely for those legal purposes.
In some circumstances you can ask us to delete your data: see request erasure below for further information.
However, an erasure request may be partially declined. In the event a complaint has been made, coupled with
an erasure request, we will maintain records relating to the complaint, including basic information such as
name, and telephone name. In the event that you do not wish to be contacted by us, we are required to
maintain a log of this request, withholding applicable data to ensure we no longer contact you further.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you)
for research or statistical purposes in which case we may use this information indefinitely without further
notice to you.

YOUR LEGAL RIGHTS
We operate under the Data Protection Act 2018 (DPA’) and UK GDPR.
The DPA and UK GDPR apply to ‘personal data’ that we process and the data protection principles. As of
19 June 2025, the Data (Use and Access) Act 2025 (DUAA) has amended UK data protection law. We have
updated our practices to ensure continued compliance and to enhance transparency in how we collect,
use, and safeguard your personal information.
Under certain circumstances, you have 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 “data 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. This enables you to ask us to delete or remove personal data
where there is no good reason for us to continue 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) and there is something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also
have the right to object where we are processing your personal data for direct marketing purposes. In
some cases, we may demonstrate that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios: (a) if you want us to establish the data’s
accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
• 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.
• Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your 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.
If you wish to exercise any of the rights set out above, please Contact us.

CHARGING FOR RIGHTS REQUESTS
You will not have to pay a fee when exercising your individual rights. However, we may charge a reasonable fee
if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your
request in these circumstances. We may also charge a further administrative fee when you request for us to
provide further copies of the information already provided to you.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or
remove information you think is inaccurate. We will respond to your request within one month of receiving
your request. We will inform you of the third parties to whom your data has been disclosed.

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 may 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.

YOUR RIGHT TO COMPLAIN TO THE INFORMATION COMMISSIONER’S OFFICE
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK
supervisory authority for data protection issues (https://ico.org.uk/global/contact-us/). We would, however,
appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first
instance by using the contact information provided within this Privacy Policy. GW Financial Solutions UK Ltd is
registered with the Information Commissioner’s Office under registration number ZA037135.