Privacy Policy

Our services are provided through personal, face to face and telephone advisory services to Regentia Lifestyle Planning Ltd clients. We ensure that any financial advisory services that we provide to you are delivered in accordance with the applicable regulatory requirements. Regentia Lifestyle Planning Ltd is also responsible for managing any complaints that may be made by you in respect of the services we provide.

This Privacy Policy explains when and why we collect your personal information as part of our provision of financial advice and explains how we use your information. If requested, we will provide you with a copy of this Privacy Policy for your records.

"We", "Us" "Our" refers to Regentia Lifestyle Planning Ltd.

Contact details:

Regentia Lifestyle Planning Ltd
Registered Address: Ground Floor, 17a Appleton Court, Durkar, Wakefield, WF2 7AR

Email: office@regentia.co.uk

Telephone: 01924 566010

For us to deliver such financial services and deal with any correspondence that may arise, we need to collect and process personal information. This makes us a "data controller".

Depending on our relationship with you (whether you are a prospective or existing client or a business partner), we will collect and use different personal information about you for different reasons.

Sometimes we will request or receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership). For example, to better understand your current and potential future circumstances and recommend appropriate financial investments, we may need access to information about your health. Details about your health might also be needed for us to make reasonable adjustments when providing our services to you.

We also use details of any unspent criminal convictions for fraud prevention purposes.

Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal information and responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals, and you should refer them to this notice.

This section will set out how we use your information.

What personal information may we collect?

• General information such as your name, address, phone numbers and email addresses, date of birth and gender.
• Identification information including passport, driving licence, national identity card (for non-UK nationals), government issued ID verification and address verification documents such as council tax letters or bank statement and evidence of benefit entitlement.
• Employment information such as job title, employment history and professional accreditations.
• Financial information:
  • Bank details
  • Financial reviews (fact finds)
  • Information relating to your personal finances such as your financial liabilities and assets, income, and outgoings
• Information obtained from carrying out identification checks and checking sanction lists and politically exposed persons (PEP) screening, including bankruptcy orders or where you have been flagged as a PEP.
• Information relevant to the services we provide, such as:
  • previous and current investments
  • information about your lifestyle
  • attitude to investment risk
  • existing plan details
  • objectives
  • copies of your will
  • information about any trusts you have
• Information contained in client review meeting records and file notes.
• Information contained in any records held by previous independent financial advisers (otherwise known as IFAs) with whom you were previously a client, and which have been transferred to us when that IFA was acquired by St. James's Place group companies, (For example, Perennial Financial Management Limited).
• Information about your family including information about your dependants.
• Information obtained during telephone recordings where applicable.
• Information such as IP address and browsing history obtained through our use of cookies. (You can find more information about this in our cookies policy in section 8 below).
• Your marketing preferences and details of your customer experience with us.
• Information which we have gathered from publicly available sources such as the electoral roll, internet search engines and social media sites where you have been flagged as a PEP and we need to carry out enhanced due diligence.

What special categories of information will we collect?

• Details about any criminal convictions and any related information which have been obtained from our sanctions checks and PEP screening. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.
• We may collect details about your health which are relevant to your application (e.g. as part of a pension need we may ask you about any medical conditions that affect you to establish whether you are deemed to be a vulnerable client or where we are applying for income protection insurance we will need to ask you about any medical conditions and information about lifestyle choices such as whether you drink alcohol or smoke so that appropriate insurance can be obtained) or where you have disclosed such information to us because it explains your risk appetite for investments.
• In limited circumstances, we may also collect other special categories of data as detailed on a separate consent form.

How will we collect your personal information?

We will collect information directly from you when:

• you register to receive our services and complete and return to us all applicable application forms; and
• you contact us by email, telephone and through other written and verbal communications.

We will also collect your personal information from:

• Your Adviser directly, and/ or Authorised Representative firm, if applicable.
• Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.
• Any records held by previous independent financial advisers (otherwise known as IFAs) with whom you were previously a client.
• Product Providers and Product Provider Platforms.
• Third parties such as SmartSearch who provide anti money laundering and fraud prevention services who we have appointed to carry out electronic ID checks, sanctions and politically exposed persons checking services.

What will we use your personal information for?

There are a number of reasons we use your personal information and for each use we need to have a "lawful basis" to do so.

We will rely on the following “Lawful Basis” when we process your "personal information":

• We need to use your personal information to enter into or perform the client agreement that we hold with you. For example, we need to use your personal information to provide our services, to arrange and implement recommendations, review your ongoing suitability of current arrangements and handle claims.
• We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you.
• We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to keep records of investments and the reasoning behind such investments, to maintain business records, to carry out due diligence, to review our business models and undertake strategic and operational business analysis.

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information", we must have an additional “lawful basis" and we will rely on the following Lawful Basis in these circumstances:

• You have given your explicit consent to our use of your special categories of personal information. In some cases, we are not able to offer you certain advice or financial products unless we have your relevant health information.
• There is a substantial public interest such as prevention and detection of fraud.
• We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.

Purpose for processing

Purpose for processing	Lawful Basis for using your personal information	Lawful Basis for using ‘your special’ categories of personal information
To carry out identification checks and checks against sanction lists and politically exposed persons (PEP) screening	It is necessary to enter into your client agreement. We have a valid business reason (to carry out necessary compliance checks). We have a legal and regulatory obligation.	It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). We need to establish, exercise, or defend legal rights. You have given us your explicit consent.
To verify your information throughout the course of our services.	It is necessary to enter into or perform your client agreement. We have a legal and regulatory obligation. We have a valid business reason (to verify your identity and to undertake client due diligence throughout the course of our relationship).	You have given us your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). We need to establish, exercise, or defend legal rights.
To set you up as a client on our client relationship management system and to communicate with you in respect of your service preferences.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to establish you as a client).	You have given us your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).
To provide services in accordance with your client agreement.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to ensure that we fulfil our contractual obligations to clients).	You have given us your explicit consent. We need to use your information in order to establish, exercise or defend legal rights.
To arrange and implement any of our recommendations e.g., investing into certain funds or arranging a product or insurance policy for you.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to ensure that we fulfil our contractual obligations to clients).	You have given us your explicit consent. We need to use your information in order to establish, exercise or defend legal rights.
To carry out annual reviews and reviews of ongoing suitability of your current arrangements	It is necessary to enter into or perform your client agreement. We have a valid business reason (to ensure that we are providing appropriate services according to your circumstances).	You have given us your explicit consent. We need to use your information in order to establish, exercise or defend legal rights.
To prevent and investigate fraud.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to prevent and detect fraud and other financial crime).	We have a substantial public interest to prevent fraud. We need to use your information in order to establish, exercise or defend legal rights.
To comply with our legal or regulatory obligations.	We need to use your information in order to comply with our legal obligations.	We need to use your information in order to establish, exercise or defend legal rights. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).
To communicate with you and resolve any complaints that you might have.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to communicate with you, record and investigate complaints and ensure that complaints are handled appropriately). We need to use your information in order to comply with our legal and regulatory obligations.	We need to use your information in order to establish, exercise or defend legal rights.
To provide improved quality, training, and security (for example, through recorded or monitored phone calls to our contact numbers or carrying out customer satisfaction surveys).	We have a valid business reason (to develop and improve the products and services we offer).	You have given us your explicit consent.
For business purposes and activities including maintaining business records, file keeping and strategic business planning.	We have a valid business reason (to run our business efficiently and effectively).	You have given us your explicit consent. We need to use your information in order to establish, exercise or defend legal rights.
To apply for and claim on our own insurance.	We have a valid business reason (to maintain appropriate insurance).	We need to use your information in order to establish, exercise or defend legal rights.
To provide marketing information where you have provided your consent.	We have a valid business reason (to maintain appropriate insurance).	We need to use your information in order to establish, exercise or defend legal rights.
To provide marketing information where you have provided your consent.	You have given us your explicit consent.	Not applicable.
To provide marketing information by post, by telephone and in other circumstances where we don't require your consent.	We have a valid business reason (to send you selected communications about other products and services we offer).	Not applicable.

Who will we share your personal information with?

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

• Third parties who provide a service in relation to the management of your investments or facilitate the arrangement of products we recommend such as product providers, portfolio and fund managers, insurers where you are buying income protection products. Where we have shared your personal information with these third parties, they will also be a data controller and responsible for how they use your personal information. Their uses of your personal information will be governed by their own fair processing notices.
• Product Providers and Product Provider Platforms.
• Third parties who provide sanctions checking services including SmartSearch.
• Compliance consultants including SJP Acquisition Services Limited and ‘The Consulting Consortium’ (TCC).
• Financial crime and fraud detection agencies.
• Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
• Selected third parties in connection with any sale, transfer, or disposal of our business.
• Our insurers.
• The police, HMRC and other crime prevention and detection agencies. Third parties and self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, adviser support specialists who assist us with day to day business operations, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.

There are a small number of instances where your personal information is transferred to countries outside of the European Economic Area ("EEA") such as when we transfer information to our other companies in the SJP group or to third party suppliers who are based outside the EEA or when third parties who act on our behalf transfer your personal information to countries outside the EEA. Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including:

• Entering into data transfer contracts and using specific contractual provisions that have been approved by European data protection authorities otherwise known as the "standard contractual clauses".
• We will only transfer personal information to companies in non-EEA countries who have been deemed by European data protection authorities to have adequate levels of data protection for the protection of personal information.

We are also entitled under European data protection laws to transfer your personal information to countries outside the EEA where it is necessary for the performance of the contract, we have with you.

Depending on our relationship and your particular circumstances, we might transfer personal information anywhere in the world.

At Regentia Lifestyle Planning Limited, we take our responsibility to look after your personal information and privacy seriously. In today’s world, we have all seen a growing trend in cybercrime and security breaches. We have a number of security measures in place to help prevent fraud and cybercrime.

If we become aware that a personal data breach has occurred and is likely to result in a high risk to the rights and freedoms of our clients, advisers, or employees, we will inform them without undue delay.

The executive body responsible for privacy and data security is the Information Security Oversight Committee (ISOC) - chaired by the Data Protection Officer. ISOC has a reporting line that enables effective escalation of issues up to the Board where appropriate.

We educate and train our employees on their information security, fraud prevention and privacy obligations annually.

Our employees take part in an annual Information Security training and awareness program and must agree to adhere to the Data Protection Act and our own Information Security Policy that are designed to keep your information safe. These are refreshed each year to reflect the current trends that are being observed across the information security landscape. Information Security awareness also forms part of our new employee induction program.

We also educate our employees in identifying potential financial crime and internal fraud; any suspicious activity is reported to our Financial Crime Prevention team.

We will always interact with you in a safe, secure, and consistent manner.

To keep your information secure and to protect our clients from fraud Regentia Financial Planning Limited will only interact with you in the following ways. If in doubt, please call Regentia Financial Planning directly for further information.

When interacting with you, we will:

• Only send funds that you have requested to be withdrawn to a verified bank account in your name.
• Verify who you are when speaking to you on the phone, by asking you security questions.

We will not:

• Ask you for your password over the phone.
• Ask you for credit card details by email or telephone.
• Call you to notify you of a problem, and then request you call us back immediately to discuss the problem further.

We continually review our physical and logical security controls in place across the business.

Physical controls – As well as protecting your digital information, Regentia Financial Planning Limited also protects their premises and physical locations where personal data may be used and stored. These measures include security entrances, secure disposal of confidential waste and hardware, locks on doors and file storage cabinets, with a ‘clear desk’ policy to ensure all information is locked away and protected.

Logical controls – Regentia Financial Planning Limited uses technical security measures to make sure our systems where we store and use personal information are protected from unauthorised access. Tools such as authentication controls, antivirus, firewalls, malware detection and back-up procedures are used across the business.

All employee emails and devices are encrypted to enable secure transfer and storage of personal information.

We conduct security testing of our applications and services in a controlled testing environment before they are made available for our clients to use on an ongoing basis.

We perform security risk assessments for each of our sites to identify and control risks.

External technical assessments are conducted by an independent external 3rd party.

Security audits and vendor due diligence are conducted on a continual basis.

We have a business resiliency plan with disaster recovery and business continuity testing.

The purpose of Business Continuity Management and the Regentia Financial Planning Limited Business Continuity Plan is to provide an effective, predefined, and documented framework to respond to an incident affecting our activities. The key drivers in developing the business recovery plans are.

• To mitigate the risks that could lead to the significant disruption of our products and services to our clients.
• To provide a recovery plan that supports a timely and full restoration of our products and services for our clients.

However, whilst we take appropriate technical and organisational measures to safeguard your Personal Information, please note that we cannot guarantee the security of any data that you transfer over the internet to us.

You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in the ways set out in this notice. Please contact us at any time using the details set out in section 11 if you wish to exercise these rights; we will not usually charge you.

We respect your rights and will always consider and assess them but please be aware that there may be some instances where we cannot comply with a request that you make as the consequence might be that:

• in doing so we could not comply with our own legal or regulatory requirements for example we are under obligations to hold records of our dealings with you for certain periods of time; or
• in doing so we could not provide services to you and would have to cancel your client agreement, for example we could not enter into investments on your behalf if we had deleted your personal information.

We will of course inform you if any of the above situations arise and if we are unable to comply with your request.

The right to access your personal information

You are entitled to a copy of the personal information we hold about you and certain details of how we use it.

We are happy to provide you with such details but in the interests of confidentiality, we follow strict disclosure procedures which may mean that we will require proof of identify from you prior to disclosing such information.

We will usually provide your personal information to you in writing unless you request otherwise. Where your request has been made electronically (e.g., by email), a copy of your personal information will be provided to you by electronic means where possible.

It would be helpful if you could please complete the Data Subject Request Form available from Regentia Lifestyle Planning Ltd to request a copy of the information we hold so that we can ensure we have all the relevant information we need to appropriately respond to your request.

The right to rectification

Please help us to keep your personal information accurate and up to date so if you believe that there are any inaccuracies, discrepancies, or gaps in the information we hold about you, please contact us and ask us to update or amend it.

The right to restriction of processing

In certain circumstances, you have the right to ask us to stop using your personal information, for example where you think that the personal information that we hold about you may be inaccurate or where you think that we no longer need to use your personal information.

The right to withdraw your consent

Where we rely on your consent to process your personal information, you have the right to withdraw such consent to further use of your personal information.

The right to erasure

You are entitled to request your personal information to be deleted in certain circumstances such as where we no longer need your personal information for the purpose for which it was originally collected it. When you exercise this right, we need to consider other factors such as our own regulatory obligation, to assess whether we can comply with your request.

The right to object to direct marketing

You have a choice about whether or not you wish to receive marketing information from us and you have the right to request that we stop sending you marketing messages at any time. You can do this by contacting us using the details set out in section 11.

Please note that, even if you opt out of receiving marketing messages, we may still send you communications which are relevant to the nature of services we offer you.

The right to object to processing

In certain circumstances, where we only process your personal data because we have a legitimate business need to do so, you have the right to object to our processing of your personal data.

The right to data portability

In certain circumstances, you can request that we transfer personal information that you have provided to us to a third party.

When you exercise this right, we need to consider other factors such as our own regulatory obligations, to assess whether we can comply with your request.

Rights relating to automated decision-making

We do not carry out any automated decision making to provide products and services to you.

The right to make a complaint with the ICO

If you believe that we have breached data protection laws when using your personal information, you have a right to complain to the Information Commissioner's Office (ICO).

You can visit the ICO's website at https://ico.org.uk for more information. Please note that lodging a complaint will not affect any other legal rights or remedies that you have.

Our website uses cookies - small text files that are stored on your computer or in your browser - to help us to monitor how visitors use our site and allow us to maintain the optimum experience for website users. The website does not store or capture personal information about you when you visit it, it merely records traffic information. This means information about all of our visitors collectively, for example the number of visits the website receives. In order to respect our visitors' rights of privacy, this information is anonymous, and no individual visitor can be identified from it.

You can disable and delete cookies by changing the appropriate setting within your browser's 'Help', 'Tools' or 'Settings' menu.

We may update this Privacy Policy from time to time. Any changes will be posted on this page, and where appropriate, notified to you directly.

Last updated: [December 2025]