Privacy Notice

How Real Wealth Partners collects, uses and protects your personal information.

If you would like this document in larger print or in another format, please contact us.

Real Wealth Partners Ltd is part of Real Wealth Group Ltd. This privacy notice explains how we collect, use, share, store and protect your personal information — including where we use artificial intelligence (AI) or automated tools.

We take your privacy seriously and are committed to handling your personal information lawfully, fairly and transparently under the UK GDPR and the Data Protection Act 2018.

Contact details

Please contact us if you have any questions about our privacy notice or the personal information we hold about you.

Post	Compliance Team, Real Wealth Partners Ltd, Office 1, First Floor, 14-18 Tib Lane, Manchester M2 4JB
Phone	0161 768 7722
Email	compliance@realwealth.co.uk

What personal information do we collect about you?

We collect information about you when you engage us for financial planning and advice. This information relates to your personal and financial circumstances. It may also include special categories of personal data, such as data about your health, where this is necessary for the provision of our services.

This information may include:

• Personal identifiers — details that help us confirm who you are, such as:
  • Your name, date of birth, address and contact details
  • National Insurance number
  • Identification documents (passport, driving licence)
• Financial and professional information — information that helps us understand your financial position, including:
  • Your income and regular spending
  • Details of your assets, liabilities, pensions and investments
  • Tax information
  • Bank account details
  • Employment information
• Special category information — only used where relevant and with your explicit consent. This could include:
  • Health information (for example, when providing insurance advice)
  • Racial or ethnic origin
  • Political opinions
  • Religious or philosophical beliefs
  • Trade union membership
  • Genetic information
  • Biometric information (where used to identify someone, such as for access or payment purposes)
  • Sex life information
  • Sexual orientation information
• Communications — to keep accurate records and meet regulatory requirements we may record:
  • Emails, notes of telephone calls and meeting notes
  • Records required to meet the FCA’s requirements
• Information relating to use of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We use this information to personalise your repeat visits to the site.
• We may also collect information when you voluntarily complete client surveys or provide feedback to us.

How we collect your personal information

We collect personal information from you:

• During meetings and calls (including video conferences) with you
• Through emails and correspondence using our client portals
• Through online forms
• From your completion of feedback surveys
• From information shared with us by your professional advisers, service providers and product providers

How we use your personal information

We use your personal information to help us deliver the services you have asked for. This may include:

• Understanding your financial situation so we can give you the right advice
• Providing recommendations that meet FCA rules on suitability
• Applying for or arranging financial products on your behalf
• Carrying out identity, fraud and anti-money-laundering checks
• Keeping accurate and compliant records
• Communicating with you about your services, plans, policies or investments
• Personalising your repeat visits to our website

Who we share your personal information with

To provide you with our services, we sometimes need to share your personal information with trusted third parties. These may include:

• Financial product providers, such as insurers, investment platforms and pension providers
• Compliance consultants, auditors and professional advisers who help us meet regulatory requirements
• Discretionary investment managers, where relevant to your service
• IT service providers and secure cloud platforms that support our systems
• Regulators and authorities, such as the FCA, HMRC and the Financial Ombudsman Service
• Our professional indemnity insurance providers
• Credit reference agencies, but only when necessary

We never sell your personal information to anyone.

Using artificial intelligence (AI) and automated tools

We may use AI tools to help us review information more efficiently and provide you with faster, more accurate and improved services. AI does not make decisions about you on its own — a human always checks the results.

Purpose of AI use

AI tools may be used within Real Wealth to support operational efficiency, improve client servicing and enhance internal oversight. Permitted uses may include:

• Drafting, summarising or refining internal documents such as meeting notes, reports, policies, procedures and communications
• Analysing client and business data to support research, financial planning processes and suitability assessments
• Assisting in the preparation and drafting of suitability reports, recommendation letters, annual review documentation and other client reporting materials, subject to adviser review and approval
• Supporting the preparation of analysis reports, cashflow modelling commentary and research summaries for internal use
• Enhancing the presentation, structure, formatting and readability of documents for you and for internal use
• Identifying patterns, inconsistencies or potential errors within data and administrative processes
• Supporting compliance monitoring activities, including file reviews, documentation checks and regulatory oversight
• Assisting with risk assessments, vulnerability identification and the detection of potential client support needs, provided AI is not used as the sole basis for decision-making
• Supporting research, workflow automation, task management and general productivity improvements where appropriate controls are in place

We do not use any systems for making automated decisions. All outputs and decisions involving AI are subject to human review and approval before being used or relied on.

Purpose and lawful basis for processing

The purpose of processing personal information using AI tools is to support administrative efficiency, improve document quality, assist with research and analysis, support suitability assessments and enhance client servicing. Our lawful bases for processing personal information using AI tools may include:

• Performance of a contract — processing may be necessary in order to provide the financial planning, advisory or related services you have requested, including preparing recommendations, reports and servicing documentation.
• Legal obligation — processing may be necessary to comply with applicable legal and regulatory obligations, including FCA requirements, record-keeping obligations, compliance monitoring, anti-financial crime requirements and the assessment of client suitability and vulnerability.
• Legitimate interests — processing may be necessary for the legitimate interests pursued by Real Wealth, including improving operational efficiency, enhancing document quality, supporting internal analysis and oversight, maintaining service standards and improving the consistency and effectiveness of our client communications. Where we rely on legitimate interests, we ensure that such processing is proportionate, has minimal privacy impact and does not override your rights and freedoms.

We only process personal information using AI tools where it is appropriate, proportionate and subject to suitable safeguards, confidentiality controls and human oversight.

Data sharing and storage

Where AI tools are used, Real Wealth will seek to ensure that:

• Only the minimum necessary personal information is processed
• Personal information is anonymised or pseudonymised where practical and appropriate
• AI processing occurs within secure business-grade environments and regulated systems where appropriate safeguards are in place
• Appropriate contractual and data processing arrangements are maintained with third-party AI providers
• Personal information is not knowingly used to train public AI models
• Transfers of personal information outside the UK or EEA are subject to appropriate safeguards in accordance with applicable data protection laws

Real Wealth currently uses versions of AI platforms, such as ChatGPT and Claude, that are designed to provide enhanced security and organisational controls. Based on the providers’ published terms, data submitted through these business services is not used to train public AI models.

Your data protection rights

You have several rights under data protection law. These help you understand and control how your personal information is used.

• Right to be informed — you can ask us to explain how we collect, use, share and store your personal information.
• Right of access — you can request a copy of the personal information we hold about you, along with details of how we use it.
• Right to rectification — if you think any of your information is wrong or incomplete, you can ask us to correct or update it.
• Right to erasure — in some situations, you can ask us to delete your personal information.
• Right to restrict processing — you can ask us to limit how we use your information in certain circumstances.
• Right to object — you can object to us using your personal information, for example for direct marketing.
• Right to data portability — you can ask us to send your personal information to you, or directly to another organisation, in a structured, commonly used electronic format.
• Rights related to automated decision-making and profiling — if a decision about you is made without human involvement, you can challenge it and ask for someone to review it.

We will respond to any request you make about your data protection rights within one month. To make a request, please contact us using the details at the top of this privacy notice.

Our lawful bases for processing your personal information

UK data protection law requires us to have a valid legal reason — called a ‘lawful basis’ — for collecting and using your personal information. The UK GDPR sets out the different lawful bases.

The lawful basis we rely on may affect which data protection rights apply to you. We’ve listed your rights above in brief.

You can read more about your data protection rights, including any exceptions, on the ICO’s website: https://ico.org.uk/for-the-public/

Contractual obligations

This is the main reason we use your personal information. We need certain details from you so we can deliver the services we have agreed to provide.

Legal obligations

Sometimes the law requires us to collect and use specific information. For example, UK anti-money-laundering laws require us to verify your identity.

Consent

In some situations, we may need your explicit consent to use special category information. We will always explain why we need this information and ask for your clear agreement before using it.

We also ask for your consent if you would like to receive updates about products or services that may interest you.

If we rely on your consent, you can withdraw it at any time.

Legitimate interests

We may keep certain personal information because we have a legitimate business reason to do so — for example, to check the suitability of our services, respond to any complaints in the future, or to meet the requirements of our Professional Indemnity insurer.

How long do we keep your personal information?

We keep the personal information we need to provide our services to you, and we take reasonable steps to make sure it stays accurate and up to date. Some information must be kept for minimum periods set by our regulator, the Financial Conduct Authority (FCA):

• Investment business — 5 years
• Pension transfers and opt-outs — kept indefinitely
• Insurance business — 3 years

We also have to keep identity-verification documents (required under UK anti-money-laundering rules) for:

• At least 5 years after our relationship with you ends
• Up to 10 years if we still have an ongoing relationship

Because these are legal requirements, we cannot delete your information before these time periods have passed.

We reserve the right to retain data for longer where we believe it is in our legitimate interests to do so. In any case, we will not keep your personal data for longer than 5 years after our relationship with you has ended.

You can ask us to delete your personal information. We will do so unless we are required to keep it for legal or legitimate business reasons.

If you would like more information about how long we keep your personal information or how we decide this, please contact us.

Information about connected individuals

We may need to collect personal information about your close family members and dependents to provide our services effectively. If this is the case, you are responsible for ensuring you have their consent to share this information with us.

If you act as a trustee or attorney, we may also need information about the relevant beneficiaries or donor(s).

We will give them a copy of this privacy notice, or ask you to pass it on if that is more appropriate.

Using cookies

We use cookies to:

• Understand how visitors use our website
• Help us create reports and improve our site

If you would like to learn more about cookies, you can visit http://www.allaboutcookies.org/. You can change your browser settings to block or delete cookies at any time. The website above explains how to do this. Please note that if you choose to block cookies, some parts of our website may not work as expected.

Marketing

We may contact you with information about our products and services, as well as those from other companies in our group that we think you might find useful.

If you have agreed to receive marketing from us, you can change your mind at any time. Just get in touch using the contact details at the top of this privacy notice.

Other websites

Our website may include links to other sites. Please remember that this privacy notice only covers our website, so we recommend checking the privacy policies of any other sites you visit.

How can you access the information we hold about you?

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details at the top of this notice.

When your personal data is processed by automated means, you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

What can you do if you are unhappy with how your personal data is processed?

If you have any concerns about how we use your personal information, you can contact us using the details at the top of this privacy notice.

If you are not satisfied with our response, you can also complain to the Information Commissioner’s Office (ICO):

Information Commissioner’s Office Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Helpline: 0303 123 1113 Website: https://www.ico.org.uk/make-a-complaint

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on our website https://www.realwealth.co.uk/privacy-policy/ and inform you of any changes when they occur. This privacy policy was last updated on 13 May 2026.

How to contact us

Please contact us if you have any questions about our privacy policy or the information we hold about you. By email at hello@realwealth.co.uk or write to us at: Real Wealth Partners Ltd, Office 1, First Floor, 14-18 Tib Lane, Manchester M2 4JB.