At Graham Carter & Co, we are committed to protecting and respecting your privacy. This Policy explains when and why we collect personal information about people who visit our website or use our services, how we use it, the conditions under which we may share it, and how we keep it secure.

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We may update this Policy from time to time. Please check this page occasionally to ensure that you are happy with any changes. By using our website and services, you agree to be bound by this Policy.

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If you have any questions, please contact us:

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📧 Email: info@grahamcarter.com

📮 Post: Graham Carter & Co, Old Bank Buildings, 2 City Road, Chester, CH1 3AE
📞 Telephone: 01244 322722

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How We Collect Information

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We obtain information when you:

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• Visit our website

• Contact us for financial advice or other services

• Complete forms, provide documents, or communicate with us

• Consent for us to obtain details from product providers

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What Information We Collect

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The information we collect may include:

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• Website visitors: name, email, IP address, pages accessed, browsing activity

• Clients: personal and financial details, objectives, investments, pensions, policies

• Sensitive data: health or medical information (e.g. for life assurance) — collected only with your consent

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How We Use Your Information

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We may use your information to:

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• Provide financial advice and recommendations

• Arrange and administer investments and policies

• Deliver our ongoing client service

• Meet our legal and regulatory obligations (including FCA requirements)

• Communicate with you about relevant actions (e.g. tax year planning, reviews)

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We will not sell or rent your information to third parties. We do not share your information for marketing purposes.

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Who Has Access to Your Information

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• Internal staff (advisers, support staff, management) — to provide advice and services

• Third-party providers (paraplanners, compliance consultants, product providers, IT support) — only as necessary, under written agreements requiring them to protect your data

• Regulators (e.g. FCA, Financial Ombudsman Service) if legally required

• Other third parties only with your consent or where required by law (e.g. fraud prevention, court order)

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How Long We Keep Information

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We retain information for as long as necessary to meet our legal, regulatory, and contractual obligations. For example:

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• Pension transfer advice – indefinitely

• Life assurance business – indefinitely

• Other regulated advice – minimum 5 to 7 years, sometimes longer depending on FCA rules

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We will not keep information longer than is necessary.

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Your Rights Under UK GDPR

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You have rights in relation to the information we hold about you:

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• Access – request a copy of your data (free of charge, within one month)

• Rectification – correct inaccurate or incomplete data

• Erasure – request deletion of data (subject to regulatory requirements)

• Restrict processing – stop us processing data, but allow us to keep it

• Data portability – request transfer to another provider where technically possible

• Object – to certain types of processing, including direct marketing

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To exercise any of these rights, please contact us.

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Security of Your Information

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We take the security of your data seriously. Measures include:

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• Secure storage on protected systems

• Encryption and password protection

• Restricted access to authorised staff only

• Ongoing staff training on data protection and confidentiality

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Please note that data transmitted over the internet (e.g. email) may not be completely secure. Once we receive your information, we apply appropriate safeguards.

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Cookies and Website Use

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Our website uses cookies to improve functionality and your experience. Some cookies are essential, while others (such as analytics) require your consent.

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You can manage cookie preferences through your browser settings or our website cookie banner. Turning off cookies may affect site functionality.

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International Transfers

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If we transfer your data outside the UK (for example, if servers or providers are located abroad), we will ensure appropriate safeguards are in place in line with UK GDPR (such as adequacy regulations or standard contractual clauses).

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Profiling

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We may use automated systems (such as risk-profiling tools) to help assess your investment objectives. These are always reviewed by an adviser before any recommendation is made.

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Your Right to Complain

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If you are unhappy with how we handle your data, please contact us first so we can try to resolve the issue.

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You also have the right to complain to the UK Information Commissioner’s Office (ICO):
🔗 www.ico.org.uk/concerns

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Review of This Policy

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We keep this Privacy Policy under regular review.

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Last updated: March 2025