Privacy Policy

Last updated: September 15, 2025

ImBothutch Limited ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website imbothutch.com and use our financial planning services.

This policy is designed to help you understand our data practices in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection laws.

1. Information We Collect

Personal Information

We may collect the following personal information from you:

  • Identity Data: Name, title, date of birth, marital status
  • Contact Data: Address, email address, telephone numbers
  • Financial Data: Income, expenditure, assets, liabilities, pension details, investment experience
  • Technical Data: IP address, browser type, operating system, referring website
  • Profile Data: Risk tolerance, investment objectives, financial goals
  • Usage Data: Information about how you use our website and services
  • Marketing Data: Your preferences in receiving marketing communications

Sensitive Personal Data

We may collect special categories of personal data including:

  • Health information (for protection insurance purposes)
  • Financial hardship information
  • Information about criminal convictions (where required for regulatory purposes)

2. How We Collect Information

Direct Collection

  • When you complete forms on our website
  • During consultations and meetings
  • Through correspondence via post, phone, email, or other means
  • When you subscribe to our newsletters or request information

Automated Collection

  • Cookies and similar tracking technologies
  • Server logs and analytics tools
  • Third-party analytics services

Third Parties

  • Product providers and pension schemes
  • Credit reference agencies
  • Regulatory bodies
  • Professional networks and referral sources

3. Legal Basis for Processing

We process your personal data on the following legal bases:

Consent

Where you have given clear consent for us to process your personal data for specific purposes, such as marketing communications.

Contract

Where processing is necessary for the performance of a contract with you or to take steps prior to entering into a contract.

Legal Obligation

Where we need to comply with legal or regulatory obligations, including:

  • Financial Conduct Authority (FCA) requirements
  • Anti-money laundering regulations
  • Tax reporting obligations
  • Record keeping requirements

Legitimate Interests

Where processing is necessary for our legitimate interests, including:

  • Providing excellent customer service
  • Improving our services and website
  • Fraud prevention and security
  • Business administration and development

4. How We Use Your Information

We use your personal information for the following purposes:

Service Provision

  • Providing financial planning and investment advice
  • Arranging financial products and services
  • Ongoing portfolio management and reviews
  • Processing applications and transactions

Legal and Regulatory Compliance

  • Compliance with FCA rules and guidance
  • Anti-money laundering checks
  • Suitability assessments and record keeping
  • Regulatory reporting

Business Operations

  • Customer service and support
  • Website functionality and security
  • Business development and improvement
  • Training and quality monitoring

Marketing and Communications

  • Sending newsletters and market updates
  • Providing relevant product information
  • Event invitations and educational content
  • Customer satisfaction surveys

5. Information Sharing and Disclosure

We may share your personal information with:

Service Providers

  • Product providers (insurance companies, fund managers, pension providers)
  • Platform providers and investment managers
  • IT service providers and cloud hosting services
  • Professional service providers (lawyers, accountants, auditors)

Regulatory Bodies

  • Financial Conduct Authority (FCA)
  • HM Revenue & Customs (HMRC)
  • Financial Ombudsman Service
  • Other regulatory or governmental authorities as required

Third Parties

  • Credit reference agencies for identity verification
  • Professional indemnity insurers
  • Business partners in joint ventures or strategic alliances
  • Potential purchasers in the event of business sale

6. Data Security

We implement appropriate technical and organisational measures to protect your personal data against:

  • Unauthorised or unlawful processing
  • Accidental loss, destruction, or damage
  • Data breaches and cyber attacks
  • Unauthorised access or disclosure

Security Measures Include:

  • Encryption of data in transit and at rest
  • Secure hosting with reputable cloud providers
  • Regular security assessments and penetration testing
  • Access controls and user authentication
  • Staff training on data protection and security
  • Incident response procedures

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including:

Client Records

Minimum 6 years after the end of our business relationship (FCA requirement)

Pension Transfer Records

Indefinitely (FCA requirement)

Marketing Data

Until you withdraw consent or we determine it's no longer relevant

Website Analytics

26 months (Google Analytics default)

8. Your Rights

Under UK data protection law, you have the following rights:

Right of Access

Request copies of your personal data

Right of Rectification

Request correction of inaccurate data

Right of Erasure

Request deletion of your data in certain circumstances

Right to Restrict Processing

Request limitation of how we use your data

Right to Data Portability

Request transfer of your data to another provider

Right to Object

Object to processing based on legitimate interests

To exercise any of these rights, please contact us at:

  • Email: [email protected]
  • Post: Data Protection Officer, ImBothutch Limited, 66-68 Severn St, Birmingham B1 1JL
  • Phone: +44 121 654 6000

9. Cookies and Tracking

Our website uses cookies and similar technologies to improve your experience. For detailed information about our cookie usage, please see our Cookie Policy.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to read their privacy policies before providing any personal information.

11. Children's Privacy

Our services are not intended for individuals under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that we have collected such information, we will take steps to delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by:

  • Posting the updated policy on our website
  • Sending you an email notification (where we have your consent)
  • Displaying a prominent notice on our website

13. Complaints

If you have concerns about how we handle your personal data, please contact us first. If you remain unsatisfied, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone: 0303 123 1113
Website: ico.org.uk

14. Contact Information

For any questions about this Privacy Policy or our data practices, please contact:

ImBothutch Limited
66-68 Severn St
Birmingham B1 1JL
United Kingdom

Email: [email protected]
Phone: +44 121 654 6000

FCA Registration: [Registration Number]
Data Protection Registration: [ICO Registration Number]