Website Privacy Notice

Effective Date: 15 September 2026

1. Introduction

Adviser Services Holdings Limited ("ASHL", "we", "us", or "our") is committed to protecting your privacy and handling your personal information fairly, lawfully and transparently.

This Privacy Notice explains how we collect, use, store, share and protect your personal information when you:

• Visit our websites;
• Use our online portals and services;
• Complete online forms;
• Contact us by telephone, email or post;
• Register an interest in our services;
• Interact with us in connection with our business activities.

Our websites and services are primarily intended for financial advisers and financial services professionals operating in the United Kingdom.

Please read this Privacy Notice carefully.

2. Who We Are

The Adviser Services Holdings Group comprises:

• Adviser Services Holdings Limited
• Sense Network Limited
• Lyncombe Consultants Limited

Depending on your relationship with us, the relevant company with which you interact will usually be the controller of your personal information.

In certain circumstances, Adviser Services Holdings Limited and another Group company may jointly determine how and why personal information is processed. Where this occurs, they will act as Joint Controllers.

3. Contact Details

If you have questions about this Privacy Notice or wish to exercise your privacy rights, please contact:

Data Privacy Lead

Email: dataprivacy@adviserservices.co.uk

Telephone: 01565 658840

Address:

Adviser Services Holdings Limited
Brookdale Centre
Manchester Road
Knutsford
WA16 0SR

4. Personal Information We Collect

Depending on how you interact with us, we may collect the following categories of personal information.

Identity Data

• Name
• Title
• Date of birth
• Username or account identifier

Contact Data

• Postal address
• Email address
• Telephone number

Adviser and Professional Data

• FCA-related information
• Professional qualifications
• Business details
• Regulatory information

Financial Data

• Bank account information
• Payment details
• Commission-related information

Transaction Data

• Payments received or made
• Service-related transactions
• Account activity

Technical Data

• IP address
• Browser type and version
• Device information
• Operating system
• Login information
• Website and portal activity

Usage Data

• Website usage information
• Browsing behaviour
• Portal activity
• Interactions with online services

Marketing and Communications Data

• Marketing preferences
• Consent records
• Communication preferences

Profile Data

• User preferences
• Feedback responses
• Survey information
• Service interests

We may also generate aggregated and anonymised information for analytical and statistical purposes.

5. Special Category Data

We do not intentionally collect special category personal information through our websites.

However, if you voluntarily provide information concerning health, vulnerability or other special category information, we may process that information where permitted by applicable law and where necessary to deal with your enquiry.

6. Information We Receive From Other Sources

We may obtain personal information from:

• Group companies;
• Publicly available sources;
• The FCA Register;
• Companies House;
• Analytics providers;
• Service providers;
• Professional advisers;
• Third-party referrals where appropriate.

7. How We Collect Personal Information

We collect information in several ways.

Information You Provide Directly

You may provide information when you:

• Complete contact forms;
• Register for events;
• Request information;
• Subscribe to communications;
• Contact us via email, telephone or post.

Automated Technologies

When you visit our website we may automatically collect Technical Data and Usage Data through:

• Cookies;
• Analytics technologies;
• Website logs;
• Similar technologies.

Further information is available in our Cookie Policy.

Third Parties

We may receive information from:

• Google Analytics;
• HubSpot;
• Website hosting providers;
• Group companies;
• Regulatory and public sources.

8. How We Use Your Personal Information

We will only use personal information where we have a lawful basis.

Contractual Necessity

We may process personal information to:

• Register advisers;
• Deliver services;
• Manage accounts;
• Provide support;
• Process payments.

Legal Obligations

We may process information to:

• Meet regulatory requirements;
• Comply with FCA obligations;
• Prevent fraud and financial crime;
• Meet legal reporting requirements.

Legitimate Interests

We may process personal information for:

• Website administration;
• Security monitoring;
• Service improvements;
• Analytics and reporting;
• Responding to enquiries;
• Business management;
• Fraud prevention;
• Corporate governance.

When relying on legitimate interests, we assess and balance our interests against your rights and freedoms.

Consent

We rely on consent where required, including:

• Non-essential cookies;
• Website analytics cookies;
• Certain marketing communications.

You may withdraw consent at any time.

9. Marketing Communications

We may provide information regarding:

• Services;
• Products;
• Events;
• Industry updates;
• Regulatory developments.

You can opt out of marketing communications at any time by:

• Clicking the unsubscribe link in emails;
• Contacting us directly;
• Updating your preferences via our Privacy Choices Centre.

Opting out of marketing will not affect service-related communications.

10. Cookies and Analytics

We use cookies and similar technologies to:

• Operate our websites;
• Improve user experience;
• Measure website performance;
• Understand how visitors use our website.

Where required by law, non-essential cookies are only placed after you provide consent.

For further information, please see our Cookie Policy.

11. Privacy Choices Centre

You can manage your privacy preferences at any time through our Privacy Choices Centre.

The Privacy Choices Centre allows you to:

• Manage cookie preferences;
• Withdraw analytics consent;
• Update marketing preferences;
• Submit privacy rights requests;
• Request deletion of personal information where applicable;
• Object to certain processing activities.

Your privacy preferences will be recorded and respected wherever technically possible across our websites.

12. Disclosing Personal Information

We may share personal information with:

Group Companies

Other companies within the Adviser Services Holdings Group.

Service Providers

Including providers of:

• Microsoft 365 services;
• Website hosting;
• IT support;
• Cloud services;
• CRM platforms;
• Analytics platforms.

Professional Advisers

Including:

• Lawyers;
• Auditors;
• Insurers;
• Accountants;
• Consultants.

Regulators and Authorities

Including:

• Financial Conduct Authority;
• Information Commissioner's Office;
• HM Revenue & Customs;
• Law enforcement agencies where required by law.

Corporate Transactions

Potential purchasers, investors or acquiring organisations where a business transfer, acquisition or restructuring is contemplated.

13. International Transfers

Some of our service providers may process personal information outside the United Kingdom.

Where personal information is transferred internationally, we ensure appropriate safeguards are in place, including:

• UK Adequacy Regulations;
• UK International Data Transfer Agreements (IDTA);
• UK Addendum to the EU Standard Contractual Clauses;
• Additional technical and organisational security measures where required.

Further information can be requested by contacting us.

14. Automated Decision-Making

We do not carry out solely automated decision-making that produces legal or similarly significant effects on individuals.

If this changes, we will provide appropriate information and safeguards in accordance with applicable data protection laws.

15. Data Security

We maintain appropriate technical and organisational measures including:

• Access controls;
• Encryption;
• Multi-factor authentication where appropriate;
• Security monitoring;
• Staff training;
• Incident response procedures.

We regularly review our security measures and investigate suspected data security incidents.

16. Data Retention

We retain personal information only for as long as necessary.

Typical retention periods include:

Where necessary, information may be retained longer in connection with legal claims, investigations or regulatory obligations.

When information is no longer required, it is securely deleted or anonymised.

17. Your Rights

You have the following rights under UK data protection laws:

• Right of access;
• Right to rectification;
• Right to erasure;
• Right to restrict processing;
• Right to object to processing;
• Right to data portability;
• Right to withdraw consent;
• Rights relating to automated decision-making.

To exercise any of these rights, please contact:

dataprivacy@adviserservices.co.uk

We will normally respond within one month.

18. Complaints

If you are unhappy with how we process your personal information, please contact us first so we have the opportunity to address your concerns.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO).

Website: www.ico.org.uk

Telephone: 0303 123 1113

19. Changes to This Privacy Notice

We may update this Privacy Notice periodically to reflect changes in our business, services, technologies or legal requirements.

The latest version will always be published on our website.

Document control

Effective Date: 15 September 2026
Last Reviewed: 15 September 2026
Next Review Date: 15 September 2027
Version: 3.0