Privacy Notice

1. Data Controller

Hadamard LLC ("we", "us", "our"), trading as approval.co.uk, is the data controller responsible for your personal data. If you have any questions about this privacy notice or how we handle your personal data, please contact us at privacy@approval.co.uk.

2. What This Notice Covers

This privacy notice explains how we collect, use, store, and share personal data when you use approval.co.uk (the "Service"). It applies to all visitors to our website and to financial advisers whose information appears on our directory.

3. What Data We Collect

3.1 Financial Adviser Data

We collect and display information about FCA-authorised financial advisers from publicly available sources, including:

• Full name, firm name, and FCA Financial Reference Number (FRN)
• FCA authorisation status, permissions, and any disciplinary history
• Business address and postcode
• Company information from Companies House (incorporation date, company status, accounts category)
• Google Places data (review ratings and review count)
• Chartered status from public professional body directories
• VouchedFor 'Top Rated' status from publicly available guides

This data is sourced from public registers and directories. We do not collect private or non-public information about advisers without their knowledge.

3.2 Consumer Data

When you use our lead enquiry form, we collect:

• Your name
• Your email address
• Your phone number
• Your postcode
• Details of your enquiry or the type of advice you are seeking

3.3 Advertising Data

We use Google AdSense to display advertisements on our website. If you consent to advertising cookies, Google may collect data including:

• Cookie identifiers and device identifiers
• IP address (which may be used to estimate general location)
• Browsing activity on our site and across other sites that use Google's advertising services
• Ad interaction data (impressions, clicks)

This data is collected and processed by Google in accordance with Google's Privacy Policy. We do not have access to the personal data Google collects through advertising cookies. Advertising cookies are only set with your explicit consent via our cookie banner.

3.4 Technical Data

We use Plausible Analytics, a privacy-focused, cookie-free analytics tool. Plausible does not collect personal data or use cookies. We may also collect limited technical data such as your IP address in server logs for security purposes.

4. Lawful Bases for Processing

We process personal data under the following lawful bases as defined by UK GDPR:

4.1 Legitimate Interests (Article 6(1)(f))

We rely on legitimate interests to process publicly available adviser data from the FCA Financial Services Register, Companies House, and other public sources. Our legitimate interest is to operate a directory that helps consumers find FCA-authorised financial advisers in their area. We have conducted a Legitimate Interest Assessment and concluded that this processing does not override the rights of data subjects, as all data is already in the public domain and the processing benefits both consumers and advisers.

4.2 Consent (Article 6(1)(a))

We rely on your explicit consent in two cases:

• Lead enquiries: When you submit a lead enquiry form, we obtain your explicit consent before sharing your personal data with the selected financial adviser.
• Advertising cookies: Google AdSense advertising cookies are only set when you explicitly consent via our cookie banner. You can withdraw consent at any time by clearing your cookie preferences.

You may withdraw your consent at any time by contacting us at privacy@approval.co.uk.

4.3 Contractual Necessity (Article 6(1)(b))

We process data as necessary to provide you with our service, including matching your enquiry with a relevant adviser and facilitating initial contact.

5. Categories of Data Processed

6. How We Share Your Data

We share consumer data only in the following circumstances:

• With the selected financial adviser: When you submit a lead enquiry, your name, email address, phone number, and postcode are shared with the adviser you have selected. This only happens with your explicit consent.
• Service providers: We use a limited number of service providers to host and operate our website. These providers process data on our behalf and under our instructions, in accordance with appropriate data processing agreements.
• Legal obligations: We may disclose data if required to do so by law or in response to valid requests by public authorities.

We do not sell your personal data. We do not share your data with third parties for direct marketing purposes. Where you have consented to advertising cookies, Google may use data collected via AdSense to show you personalised ads across its network, as described in section 3.3 above and in our Cookie Policy.

7. Data Retention

• Consumer lead data: Lead enquiry submissions are deleted after 24 months from the date of submission. If you withdraw consent before this period, your data will be deleted promptly.
• Adviser data: Adviser information is refreshed periodically from public registers. We do not retain historical adviser data beyond the current snapshot from the relevant public register.
• Server logs: Technical server logs are retained for a maximum of 90 days for security and operational purposes.

8. Your Rights Under UK GDPR

You have the following rights in relation to your personal data:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request that we correct any inaccurate or incomplete personal data.
• Right to erasure: You may request that we delete your personal data, subject to any legal obligations we may have to retain it.
• Right to restriction: You may request that we restrict the processing of your personal data in certain circumstances.
• Right to object: You may object to our processing of your personal data where we rely on legitimate interests as our lawful basis.
• Right to data portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

9. How to Exercise Your Rights

To exercise any of your rights, please email us at privacy@approval.co.uk. We will respond to your request within one month. In exceptional circumstances, we may extend this period by a further two months, in which case we will inform you of the extension and the reasons for it.

We may ask you to verify your identity before processing your request, to ensure the security of your personal data.

10. Complaints

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

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

We would appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

11. Cookies and Advertising

We use essential cookies and, with your consent, advertising cookies from Google AdSense. For detailed information about the cookies we use, how Google AdSense works, and how to manage your preferences, please see our Cookie Policy.

12. Changes to This Notice

We may update this privacy notice from time to time to reflect changes in our practices or for legal, regulatory, or operational reasons. We will update the "Last updated" date at the top of this page when changes are made. We encourage you to review this notice periodically.

13. Contact Us

If you have any questions about this privacy notice or our data practices, please contact us at:

• Email: privacy@approval.co.uk