Privacy Policy

1. Introduction

ProGeb Financial Ltd ("we," "our," or "us") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at progebregm.com or use our financial planning services.

We are registered as a data controller with the Information Commissioner's Office (ICO) under registration number Z1234567. This policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

2.1 Personal Information You Provide

We collect information that you voluntarily provide to us, including:

• Contact Information: Name, email address, phone number, postal address
• Financial Information: Income, assets, liabilities, investment experience, risk tolerance
• Identification Information: Date of birth, National Insurance number, passport/driving licence details
• Family Information: Marital status, dependents, beneficiary information
• Professional Information: Employment details, occupation, employer information

2.2 Automatically Collected Information

When you visit our website, we may automatically collect:

• IP address and device information
• Browser type and version
• Pages visited and time spent on site
• Referring website information
• Cookies and similar tracking technologies (see Cookie Policy)

2.3 Third-Party Information

We may receive information from:

• Credit reference agencies for affordability assessments
• Other financial institutions with your consent
• Publicly available sources for verification purposes

3. How We Use Your Information

3.1 Lawful Basis for Processing

We process your personal information based on the following lawful bases:

• Contract Performance: To provide financial planning services you've requested
• Legal Obligations: To comply with FCA regulations and anti-money laundering requirements
• Legitimate Interests: To improve our services and prevent fraud
• Consent: For marketing communications and non-essential cookies

3.2 Purposes of Processing

We use your information to:

• Provide financial advice and planning services
• Assess your financial needs and risk profile
• Recommend suitable financial products and services
• Process applications and transactions
• Maintain ongoing client relationships
• Comply with regulatory requirements and legal obligations
• Prevent fraud and ensure system security
• Send service updates and important notices
• Provide customer support and respond to inquiries
• Improve our website and services

4. Information Sharing and Disclosure

4.1 When We Share Information

We may share your personal information in the following circumstances:

Service Providers

• Technology service providers (cloud hosting, data processing)
• Professional service providers (legal, accounting, compliance)
• Marketing service providers (with your consent)

Financial Product Providers

• Insurance companies for policy applications
• Investment platforms for portfolio management
• Pension providers for transfers and contributions

Regulatory and Legal Requirements

• Financial Conduct Authority (FCA)
• HM Revenue & Customs (HMRC)
• Court orders and legal proceedings
• Law enforcement agencies when required by law

4.2 International Transfers

We may transfer your data to countries outside the UK where our service providers are located. All international transfers are protected by:

• Adequacy decisions by the UK government
• Standard contractual clauses approved by the ICO
• Other appropriate safeguards as required by UK GDPR

5. Cookies and Tracking Technologies

We use cookies and similar technologies to improve your experience on our website. For detailed information about our cookie practices, please see our Cookie Policy.

5.1 Types of Cookies We Use

• Essential Cookies: Required for website functionality
• Analytics Cookies: Help us understand website usage (with consent)
• Marketing Cookies: Enable personalized advertising (with consent)

5.2 Managing Cookie Preferences

You can manage your cookie preferences through:

• Our cookie consent banner
• Your browser settings
• Contacting us directly

6. Your Data Protection Rights

Under UK GDPR, you have the following rights regarding your personal information:

6.1 Right of Access

You can request a copy of the personal information we hold about you.

6.2 Right to Rectification

You can ask us to correct inaccurate or incomplete personal information.

6.3 Right to Erasure

You can request deletion of your personal information in certain circumstances.

6.4 Right to Restrict Processing

You can request that we limit how we use your personal information.

6.5 Right to Data Portability

You can request a copy of your data in a machine-readable format.

6.6 Right to Object

You can object to processing based on legitimate interests or for marketing purposes.

6.7 Rights Related to Automated Decision Making

You have rights regarding automated decision-making and profiling.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

7.1 Security Measures

• Encryption of data in transit and at rest
• Access controls and user authentication
• Regular security assessments and penetration testing
• Staff training on data protection and security
• Secure disposal of data when no longer needed

7.2 Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

• Notify the ICO within 72 hours of becoming aware of the breach
• Inform affected individuals without undue delay if there is a high risk
• Take immediate steps to contain the breach and prevent further damage

8. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by law.

8.1 Retention Periods

• Client Records: 6 years after the end of our relationship (FCA requirement)
• Marketing Data: Until you withdraw consent or we determine it's no longer needed
• Website Analytics: 26 months from collection
• CCTV Footage: 30 days unless required for investigation

8.2 Secure Disposal

When data is no longer needed, we securely delete or destroy it using industry-standard methods to prevent recovery.

9. Contact Information and Complaints

9.1 Data Protection Officer

For any questions about this Privacy Policy or how we handle your data, please contact:

9.2 Complaints

If you're not satisfied with how we've handled your personal information, you have the right to make a complaint to the Information Commissioner's Office (ICO):

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make changes, we will:

• Update the "Last updated" date at the top of this policy
• Notify you of significant changes via email or website notice
• Obtain your consent for changes that require it under applicable law

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.