1.1 Bluechip Financial Ltd is committed to protecting and respecting your privacy. We are the data
controller and will process your personal data in accordance with the Data Protection Act 1998 as
amended or replaced by the General Data Protection Regulation 2016 and any national laws which
relate to the processing of personal data (“data protection legislation”).

1.2 Please read the following carefully to understand our views and practices regarding Your Data
and how we will treat it.
This policy applies to information we collect about:
• Visitors to our website
• Customers
• Introducers
• Suppliers


2.1 We may collect and process personal data about you in the following circumstances:

2.1.1 when you complete the online contact forms on our website (“Site”) providing us with your name, address, email address and contact number;

2.1.2 whenever you provide information to us when reporting a problem with our Site,
making a complaint, making an enquiry or contacting us for any other reason. If you contact
us, we may keep a record of that correspondence;

2.1.3 when you visit our Sites we will retain details such as traffic data, location data,
weblogs and other communication data, and the resources that you access (see section 2.2.2
on Cookies below); and

2.1.4 whenever you disclose your information to us, or we collect information from you in
any other way, through our Sites.

2.2 We may also collect data in the following ways:
IP Address

2.2.1 We may collect information about your device, including where available your Internet
Protocol address, for reasons of fraud protection. We may also collect information about
your device’s operating system and browser type, for system administration and to report
aggregate information to our advertisers. This is statistical data about our users’ browsing
actions and patterns, and does not identify any individual.

2.2.2 Our Sites uses cookies to distinguish you from other users of our Sites. This helps us to
provide you with a good experience when you browse our Sites and also allows us to
improve our Sites. For detailed information on the cookies we use and the purposes for
which we use them see our Cookie Policy

2.3 We may use your personal data for our legitimate interests in order to:

2.3.1 provide you with information, or services that you requested from us;

2.3.2 respond to an enquiry submitted via our online contact forms;

2.3.3 allow you to participate in interactive features of our Sites, when you choose to do so;

2.3.4 ensure that content from our Sites are presented in the most effective manner for you
and for your device;

2.3.5 improve our Sites and services;

2.3.6 process and deal with any complaints or enquiries made by you; and

2.3.7 contact you for marketing purposes where you have signed up for these (see section 5
for further details).

Website Links
Our Site may, from time to time, contain links to and from the websites of third parties.
Please note that if you follow a link to any of these websites, such websites will apply
different terms to the collection and privacy of your personal data and we do not accept any
responsibility or liability for these policies. Please check before you submit your information
to these websites.


3.1 We will collect details such as name, address, email address, contact number, date of birth,
national insurance number and financial information in order to provide services to customers. We
may also receive details of credit checks undertaken where you have supplied these to us.

3.2 We will share customer personal information with our employees to manage our relationship
with you and we will retain customer personal data for 80 years.

3.3 We will use your personal data provided to comply with our contractual obligations arising from
the agreements we enter into with our Customers and share the data with financial institutions who
can assist in the provision of financial services to customers including product providers, lenders,
banks, insurers, fund managers, platform providers and third party para-planners.

3.4 We will use customer personal data for our legitimate interests including:

3.4.1 sharing personal data with Peritus Private Finance Ltd as they are responsible for the
services we provide to our clients and have a legal obligation to monitor our compliance
with the FSMA and Financial Conduct Authority rules.

3.4.2 with your consent, marketing our other products and services by mail and email; and

3.4.3 with your consent, obtaining your sensitive personal data from third parties including
your health, ethnic origin, or criminal prosecutions from third parties such as employers and
credit reference agencies, fraud prevention agencies and other similar organisations.

3.5 We may transfer your personal data to the following which are located outside the European
Economic Area (EEA) as follows:

United States in order to store your client data safely within Dropbox.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst
the European Commission has not given a formal decision that United States provide an adequate
level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of
your personal data will be subject to the EU-U.S. Privacy Shield Framework which is designed to help
safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your
personal data. To obtain a copy of such safeguards please refer to the following guidance and
confirmation of Dropbox participating in the framework.

You have a right to ask us for more information about the safeguards we have put in place as
mentioned above.


We will collect details such as contact names, address, email address and telephone number in order
to contact you about goods and/or services we have ordered from you, to comply with our
contractual obligations and to place further orders. We may share your personal data with our
employees to manage our relationship with you and we will keep your personal data for as long as
we require your goods and/or services subject to a maximum of six years from the date of our last
contact with you. We may transfer your personal data to the United States which are located
outside the European Economic Area (EEA) as per point 3.5.


5.1 We may use customer personal data to provide you with details about our services, products,
business updates and events which we think may be of interest.

5.2 You have the right to opt-out of receiving the information detailed in section 5.1 at any time. To
opt-out of receiving such information you can:

5.2.1 tick the relevant box situated in the form on which we collect your information;

5.2.2 clicking the unsubscribe button contained in any such communication received; or

5.2.3 email us at enquirie[email protected] or call 01202 692222 providing us with
your name and contact details.

5.3 Where you have subscribed to receive marketing correspondence from us we will keep your
personal data for six years from when you subscribed to receiving marketing information from us or
until you unsubscribe from receiving such correspondence from us (whichever is earlier).


6.1 In accordance with data protection legislation we are required to notify you of the legal basis
upon which we process your personal data. We process your personal data for the following

6.1.1 for performance of a contract we enter into with you;

6.1.2 where necessary for compliance with a legal obligation we are subject to; and

6.1.3 for our legitimate interests (as described within this policy).

6.2 We will also process your personal data including personal sensitive data where we have
obtained your explicit consent.


7.1 In addition to the third parties mentioned previously in this policy, we may disclose your
personal data to third parties for the following legitimate business purposes:

7.1.1 staff members in order to facilitate the provision of services to you;

7.1.2 IT software providers that host our website and store data on our behalf; and

7.1.3 to a prospective buyer of some or all of our business or assets, in which case personal
data including Your Data will also be one of the transferred assets.

7.2 We may disclose your personal data to the police, regulatory bodies, legal advisors or similar
third parties where we are under a legal duty to disclose or share your personal data in order to
comply with any legal obligation, or in order to enforce or apply our agreements; or to protect our
rights, property, or safety of our customers, or others. This includes exchanging information with
other companies and organisations for the purposes of fraud protection and credit risk reduction.

7.3 We will not sell or distribute your personal data to other organisations without your approval.


We may transfer your personal data to the United States which are located outside the European
Economic Area (EEA) as per point 3.5. Where this is required in the future, we will ensure that
safeguards are in place so that such transfers comply with data protection legislation.


9.1 Information you provide to us is shared on our secure servers. We have implemented
appropriate physical, technical and organisational measures designed to secure your information
against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit
access to personal data to those employees, agents, contractors and other third parties that have a
legitimate business need for such access.]

9.2 Where we have given you (or where you have chosen) a password which enables you to access
certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not
to share a password with anyone.

9.3 Unfortunately, the transmission of information via the internet is not completely secure.
Although we will do our best to protect your personal data, we cannot guarantee the security of
your information transmitted to our Site; any transmission is at your own risk.


10.1 It is important that the personal data we hold about you is accurate and current. Please keep us
informed if the personal data we hold about you changes.

10.2 Data protection legislation gives you certain rights in relation to your personal data. You have
the right to object to the processing of your personal data in certain circumstances and to withdraw
your consent to the processing of your personal data where this has been provided.

10.3 You can also ask us to undertake the following:

10.3.1 update or amend your personal data if you feel this is inaccurate;

10.3.2 remove your personal data from our database entirely;

10.3.3 send you copies of your personal data in a commonly used format and transfer your
information to another entity where you have supplied this to us, and we process this
electronically with your consent or where necessary for the performance of a contract;

10.3.4 restrict the use of your personal data; and

10.3.5 provide you with access to information held about you and for this to be provided in
an intelligible form.

10.4 We may request specific information from you to help us confirm your identity. Data protection
legislation may allow or require us to refuse to provide you with access to some or all the personal
data that we hold about you or to comply with any requests made in accordance with your rights
referred to above. If we cannot provide you with access to your personal data, or process any other
request we receive, we will inform you of the reasons why, subject to any legal or regulatory

10.5 Please send any requests relating to the above to our Data Lead at Bluechip Financial, 17 Moor
Road, Broadstone BH18 8AZ specifying your name and the action you would like us to undertake.
Note that in relation to requests to access personal data, we reserve the right to charge a reasonable
fee to comply with your request.


Where you have provided your consent to the collection, processing and transfer of your personal
data, you may withdraw that consent at any time. This will not affect the lawfulness of data
processing based on consent before it is withdrawn. To withdraw your consent please contact us at
17 Moor Road, Broadstone BH18 8AZ.


We reserve the right to update this privacy policy at any time, and any changes we make to our
privacy policy will be posted on this page. We will notify you if there are any changes to this policy
that materially affect how we collect, store or process your personal data. If we would like to use
your previously collected personal data for different purposes than those we notified you about at
the time of collection, we will provide you with notice and, where required by law, seek your
consent, before using your personal data for a new or unrelated purpose. We may process your
personal data without your knowledge or consent where required by applicable law or regulation.


We have appointed a Data Lead to oversee compliance with this privacy policy. If you have any
questions, comments or requests regarding this policy or how we use your personal data please
contact our Data Lead at 17 Moor Road, Broadstone BH18 8AZ – 01202 692222. This is in addition to
your right to contact the Information Commissioners Office if you are unsatisfied with our response
to any issues you raise at

Last updated: April 2022.