Privacy

Sandringham Financial Partners Ltd (“Sandringham”) are a leading provider of financial advice within the UK. We take the privacy and protection of your personal information seriously. So we’ve set out below information about our processing of your personal information, what rights you have, and how you can get in touch if you want to know more.

When we say personal information, we mean information about you, such as your name, date of birth, marketing preferences, employment details, information about your finances, and contact details.

This Privacy Notice relates to Sandringham Financial Partners Ltd, a wholly owned subsidiary of M&G plc.

Contact us

If you want to exercise your data protection rights as explained below, or if you require any other information about any other part of this Privacy Notice, you can contact us in a number of different ways.

Write to us at: The Data Protection Officer, Customer Service Centre, Lancing, BN15 8GB

Call us on: 0800 000 000 or : https://client.sandringham.co.uk/.

How we collect your data

We obtain information about you during interaction with your financial adviser, from information supplied by you directly to us or our representatives by telephone, face to face meeting or email, from information requested from financial product providers or information you provide via our websites.

We may also collect personal information about you from third parties and public sources, as explained below.

PART A - What information is being collected

We collect the personal information about you for the purposes set out below at “Why we process your data”.

We collect and use many different kinds of personal information for different purposes, and group them together like this:

Type of personal information	Description
Contact and geolocation	Where you live and how to contact you.
Financial	Your financial position, status and history.
Socio-Demographic	This includes details about your work or profession, age and nationality.
Social Relationships	Information about your partner, spouse and family.
Contractual	Details about the products or services we provide to you.
Communications	What we learn about you from letters, emails and conversations between us, and your marketing preferences.
Open Data and Public Records	Details about you that are in public records, such as the Electoral Register, and information about you that is openly available on the internet (such as business-oriented social networks).
Usage / Behavioural Data	Other data about how you use our websites, apps, platforms, products and services.
Documentary Data	Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence or birth certificate.
Special types of data	The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law requires or allows us to do so, such as where we need to process it for a substantial public interest or to protect someone’s vital interests (for example, processing information collected in respect of a vulnerable person): Racial or ethnic origin Religious or philosophical beliefs Trade union membership Personal data relating to health, genetics, biometric identifiers and sexual orientation Criminal convictions and offences
Consents	Any permissions, consents or preferences that you give us.
National Identifier	A number or code given to you by a government or official body to identify who you are, such as a National Insurance number.

We may monitor or record calls or any other communication we have with you. This might be for training, for security, to help us check for quality or for monitoring compliance with the Financial Conduct Authority (FCA)’s Consumer Duty.

If you choose not to give personal information

We may need to collect and use certain personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations or obtaining the products and services requested. It could mean that we cancel a product or service you have with us. We will notify you at the time if this is the case.

Any personal information that we collect directly from you which is optional will be made clear at the point of collection from you.

Acting on someone else’s behalf?

If you give us personal information about another person (or persons), we’ll take that to mean they have appointed and authorised you to act on their behalf. This includes providing consent to:

our processing of their personal information and sensitive personal information (as we’ve explained above)
you getting any data protection notices on their behalf.

If for any reason you are concerned as to whether you are permitted to provide us with the other person’s information, please contact us on the phone number above before sending us anything.

PART B - Why we process your data

We may use your personal information to:

provide you with information you’ve requested about our products and / or services – we will need to collect and process personal information that is necessary for us to provide you with the product or service you’ve requested;

administer our products and/or services, including to enable us to perform our obligations to you and to provide any relevant services as discussed with you prior to any purchase of a product or service;

to gain insight into how our products/services are used and how they might be improved;

carry out our obligations arising from any contracts entered into by you and us to:
- provide you with financial advice;
- act as your agent to purchase financial services products;
- provide our Precision ongoing client service;
comply with any legal or regulatory obligation to which we are subject;
process any remuneration you have agreed to pay your financial adviser;
carry out any relevant conflict checks, anti-money laundering and sanctions checks and fulfilling our obligations under any relevant anti-money laundering law or regulation (including under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended));
provide a customised experience via our Wealth Platform client portal or other websites;
deal with any complaints which may arise in the future;
send you any direct marketing communications that you opt in to;
provide you with information about other products and / or services we offer that are similar to those that you have already used or enquired about and that we think may be of interest to you;
seek your views or comments on the services we provide;
notify you of changes to our services;
send you communications which you have requested;
keep your information accurate and up to date on record and carry out other internal business administration;
perform automated decision-making, profiling or data analysis, including to build, train and audit Artificial Intelligence models (see Part F below);
prevent illegal activity or to protect our interests;
fulfil the legitimate interests of the company (see below).

Consent

To the extent that we need your consent to use your personal information for the purposes described above, you explicitly provide your consent by confirming to our representative/ticking the relevant boxes/submitting an online form/signing a form as appropriate. You have the right to withdraw your consent in such cases, but doing so may affect our ability to fulfil our contractual obligations or obtain the products and services requested – see Part H below.

Legitimate interests

One of a number of lawful reasons that we can use (or ‘process’) your personal information is ‘legitimate interests’. This means that we are permitted to use your personal information for activities which we consider necessary for the purposes of our legitimate interests or those of a third party, unless those interests are outweighed by your own interests and rights relating to protection of your personal information.

This means when you provide your personal details to us we may use your information for our legitimate business interests in, for example, growing our business through insights gained from data analysis or from sending out direct marketing content, or in carrying out our work providing you with professional financial advice and access to high quality financial products. Before relying on legitimate interests, we carefully consider and balance any potential impact on you and your data protection rights.

Examples of how and when we use this approach are:

Transfer of business to Sandringham: When your financial adviser joins our business, we will transfer your details and details of any fees or commission payments currently being made to the adviser onto our systems. We may then contact you for your agreement that any ongoing fees paid to your adviser are paid to them via Sandringham.
Processing of commission payments: Certain types of financial products pay your financial adviser a commission payment as part of the policy agreement with you. In order to process these commission payments we may need to process some of your personal information.
Profiling and Artificial Intelligence: see Part F below.
Direct marketing: We may rely on legitimate interests to send you direct marketing by post, or by electronic means if permitted by law and if our interest in doing so is not outweighed by your own data protection rights and interests . In this regard, we will also hold and use information about you so that we can respect your preferences for being contacted by us. For further information on direct marketing, see Part D below.

Your interests

When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

PART C - we share your data

We will not sell or rent your personal information to third parties.

Your personal data will be treated as strictly confidential and will be shared only with members of our corporate group, our Business Partners (see below) and other third parties for the purposes described in this Privacy Notice, or as otherwise required by law, a court order or for the prevention or detection of crime. Your data may be transferred to the Financial Conduct Authority or any other statutory, governmental, law enforcement or regulatory body as well as other parties including auditors or insurers if required.

M&G plc: As part of M&G plc, Sandringham may disclose your personal information to any member of our group (see list of key M&G plc entities here), which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

Third Party Service Providers working on our behalf: We may pass your information to our Business Partners and Marketing Partners for the purposes set out in this Privacy Notice, including completing tasks and providing services to you on our behalf. However, when we use such third party service providers, we disclose only the personal information that is necessary to perform the relevant purpose, and we will ensure we have contracts or other measures in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to any third parties for them to use for their own direct marketing purposes, unless you have requested us to do so.

Third Party Product Providers we work in association with: Our Business Partners and Marketing Partners include third-party financial product providers with whom we work closely to bring you a range of quality and reliable financial products and services. When you enquire about or purchase one or more of these products, the relevant third-party product provider will use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them. In some cases, they will be acting as a Controller of your personal information and therefore we advise you to read their Privacy Policy. These third-party product providers will share your information with us which we will use in accordance with this Privacy Notice.

The Business Partners and Marketing Partners we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you.

International transfers: As Sandringham is part of M&G plc (a global company), and some of our Business Partners are global companies, we might need to send your personal information to countries that have different data protection laws to the UK or the European Economic Area. These transfers will only be to countries in respect of which the European Commission and, where applicable, the UK Government has issued a data protection ‘adequacy’ decision, or to other countries, such as India or the United States of America, but only where appropriate safeguards have been put in place first. In more limited circumstances, we may also need to rely on a derogation under applicable privacy laws.

If you want to know more about these safeguards – like our use of the European Commission’s or UK’s Model Standard Contractual Clauses which govern the transfer of information outside of the European Economic Area and UK respectively – from privacy.team@mandg.com.

Other disclosures: Notwithstanding the terms of this Privacy Notice, we may disclose your personal data to third parties:

in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets; or
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or
to protect the rights, property, or safety of Sandringham, our service, our users and any third party we interact with to provide the services.

PART D - Direct marketing

We may send you direct marketing communications by email, post, SMS, telephone and push notification, based on personal information that you have provided to us, or that we’ve obtained from other sources or from profiling that we have carried out (see below).

If you’ve decided to opt in to receiving direct marketing communications from us by confirming to our representative/ticking the relevant boxes/submitting an online form/signing a form as appropriate we, Sandringham Financial Partners Ltd and our Marketing Partners will continue to send these to you by the method you have chosen (electronic and/or non-electronic means including post) unless you change your mind.

We may also send you direct marketing content about products or services that we think may be of interest to you, unless you’ve opted out.

Your choices

You have a choice about whether or not you wish to receive direct marketing communications from us. If you do not want to receive direct marketing communications from us about the products and services we feel may be of interest to you, then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information, or if you later decide to opt out it’s easy to let us know: you can either unsubscribe from any emails we send you or write to the address shown in the Contact Us section above. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted in that way.

Please note that opting out of one method of marketing, such as emails, won’t mean you will be opted out of all marketing. You have the right to object to us using your personal information for direct marketing – see “Your rights” below.

PART E - Sources of personal information

Sandringham may collect personal information about you directly from you, or from third parties, including:

our Business Partners and Marketing Partners;
data brokers and data suppliers, and service providers that help us to maintain data accuracy, such as Experian;
referral sites, such as Unbiased or VouchedFor;
publicly available sources (such as Companies House), or other information openly available on the internet (such as business-oriented social networks).

The categories of your personal information we may obtain from such sources are: name, professional/business contact details, marketing preferences, geolocation, information about your finances and employment information. We do this activity for marketing purposes as set out in Part A above, including our legitimate interest in exploring ways to develop our business through profiling of potential customers/referrals, market research and direct marketing opportunities. We also use this personal information to perform automated decision-making, profiling or data analysis, including to build, train and audit Artificial Intelligence models (see Part F below).

When we collect personal information from third party sources, established internal controls aim to ensure that the third-party source was permitted to provide this information to Sandringham and that we may use it for these purposes. You have the right to object to us using your personal information for direct marketing – see Part H below.

PART F – Profiling, Automated Decision Making and Artificial Intelligence

We, Sandringham, our Business Partners and our Marketing Partners may use your personal information to make automated decisions affecting you or to conduct other profiling (for example, marketing profiling). We may use a variety of technology solution to process your data, including Artificial Intelligence technology. This may include Artificial Intelligence technology training with your data. Your data will be anonymised wherever possible prior to any model training unless the model is private to Sandringham. We will always strive to ensure that any use of Artificial Intelligence includes appropriate human oversight and is compliant with applicable laws and regulations.

We use automated processes to help us provide more personalised marketing of our products/services. We create a marketing profile for you using information such as:

your name, age, gender and contact details;
your wealth information, household information, geolocation and which products/services of ours you have invested in;
behavioural data (such as data relating to your use of our websites – see our Cookie Policy);
details of our interactions with you.

Our profiling process analyses this data to determine products, services or offers which we think you may be interested in, and the best means by which to contact you. Information we collect about you in relation to one of our companies may be may be used, where permitted to do so, in relation to marketing other products from our group.

We may also use and combine your personal information together with information about other individuals, to help us to decide what marketing may be of interest to individuals with similar characteristics to you.

To the extent that we conduct such automated decision making activity, we’ll provide you with further information at the appropriate time.

PART G - How long we will keep your personal information

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example, our regulator, the Financial Conduct Authority require that records of our advice are kept for certain periods, in most cases this is at least 5 years but, in some cases, e.g. relating to pension transfers, may be indefinitely). We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is necessary to fulfil our legal and statutory obligations, or for as long as you have signed up to receive (or haven’t opted out of receiving) direct marketing communications from us, or longer if required by law or as is otherwise necessary. As FCA regulated advisers we are required to retain records relevant to our advice to you. If you require details of the statutory retention periods for the differing product types and classes of data please ask us.

PART H - Your rights

When it comes to how we use your personal information, you’ve got the right to:

request a copy of your personal information for free (we may charge you for this if the request is manifestly unfounded or excessive);
in certain circumstances request that we move your personal information to another organisation if you want us to;
request that we correct anything that’s wrong, or complete any incomplete personal information;
ask us to delete your personal information if it is no longer needed for the purposes set out in Part B or if there is no other legal basis for the processing;
limit how we use your personal information or withdraw your consent you have given for the processing of your personal information – this does not affect the lawfulness of our processing based on consent before its withdrawal;
opt out of direct marketing, and / or object to us using your personal information for direct marketing or other processing based on legitimate interests;
complain to a data protection authority or another independent regulator about how we’re using it. Find out how to complain to the Information Commissioner’s Office here.

If you want to do any of these things, or would like an explanation as regards these rights, we’ve explained how you can get in touch in the Contact Us section.

We have appointed a Data Protection Officer who can be reached at the address shown in the Contact Us section of this document.

In this Privacy Notice:

“Business Partners” means our service providers, accountants, auditors, IT service and platform providers, intermediaries, reinsurers, retrocessionaires, investment managers, agents, pension trustees (and other stakeholders), scheme advisors, introducers, selected third party financial and insurance product providers, and our legal advisers;

“Marketing Partners” means our service providers, intermediaries, pension trustees (and other stakeholders), scheme advisors, introducers and selected third party financial and insurance product providers.

Last updated March 2025.

Cookies

Cookies are small bits of text that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you and can then tailor what you see on the screen.

Some of the cookies we use:

Certain cookies are necessary in order for you to use our websites. These are used ‘in-session’ each time you visit and then expire when you leave the site. They’re not stored on your computer and they don’t contain any personal data. However, you can delete them via your browser if you wish to, but this may restrict the functions that you’re able to carry out on our sites.

Session cookies

These enable you to carry out some essential functions on our sites, they also help by minimising the need to transfer information across the internet. They are not stored on your computer and they expire when you terminate your browser session or logout of certain areas.

Analytics

We like to keep track of what pages and links are popular and which ones don’t get used so much to help us keep our sites relevant and up to date. It’s also very useful to be able to identify trends of how people navigate (find their way through) our sites and help us provide a more friendly solution.

Third-party cookie

Google Analytics tracking (and most web tracking software) uses cookies in order to provide meaningful reports about site visitors. However, Google Analytics cookies do not collect personal data about website visitors.

Managing your cookies

You’ll find more information about cookies at www.allaboutcookies.org, which gives details on how to delete cookies from your computer. For information on how to do this on your mobile phone browser, please see your handset manual.

Cookies are used on our site to ensure that we give you the best experience on our website. Some cookies are essential so you can move around the website and use its features. Without these cookies, some services you’ve asked for can’t be provided. These cookies don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet.

Changes to our Privacy Notice

We keep this Privacy Notice under regular review and we reserve the right to modify this Privacy Notice at any time. You will be notified of any future material changes we may make to our Privacy Notice and these will be made available to you.