Privacy Policy

If you would like this document in larger print or in another format, please contact us.

Via post

AS Financial, 10-16 Elm Street, London WC1X 0BJ

Via phone

020 3301 6690

Via email

info@as-financial.com

We will collect or use your personal information when you engage us for mortgage and protection (insurance) advice.

This information may include:

·      Personal identifiers – details that help us to confirm who you are, such as:

–          Your name, date of birth, address, contact details

–          National insurance number

–          Identification documents (passport, driving licence)

·      Financial and professional information – Information that helps us understand your financial position including:

–          Your income and regular spending

–          Details of your assets and liabilities

–          Tax information

–          Bank account details

–          Employment information

–          We may also need to use special category information, but only, where relevant and with your explicit consent. This could include:

o   Health information (for example, when providing protection advice)

·      Communications – to keep accurate records and meet regulatory requirements we may record:

–          Emails, notes of telephone call, meeting notes

–          Records required to meet the FCA’s requirements

We collect personal information directly from our clients during meetings, calls and emails.  

We use your personal information to help us deliver the services you’ve asked for. This may include:

• Understanding your financial situation so we can give you the right advice
• Providing recommendations that meet FCA rules on suitability
• Applying for or arranging financial products on your behalf
• Carrying out identity, fraud and anti‑money‑laundering checks
• Keeping accurate and compliant records
• Communicating with you about your services, plans, policies or investments

To provide you with our services, we sometimes need to share your personal information with trusted third parties. These may include:

• Financial product providers such as insurers and lenders
• Compliance consultants, auditors and professional advisers who help us meet regulatory requirements
• IT service providers and secure cloud platforms that support our systems
• Regulators and authorities such as the FCA, HMRC and the Financial Ombudsman Service
• Credit reference agencies, but only when necessary

We never sell your personal information to anyone.

We may use AI tools to help us review information more efficiently and provide you with faster, more accurate services. The AI doesn’t make decisions about you on its own — a human always checks the results.

When we do:  

Purpose of AI use

AI tools may be used to:

• Record meetings
• Draft or summarise internal documents (e.g., meeting notes)
• Enhance compliance monitoring

We do not use any systems for making automated decisions. All outputs and decisions made by AI are subject to human review and approval before being used or relied on.

Lawful basis for processing

Our lawful basis for using AI to process your personal information is Legitimate Interest, see Our Lawful Bases for Processing Your Personal Information. 

Human review

Any AI assisted output is reviewed by a human adviser before being used or relied on.

Data sharing and storage 

Where AI tools are used, we will:

• Ensure only the minimum necessary personal information is processed
• Anonymise or pseudonymise, where possible, personal information
• Ensure processing occurs in secure, regulated systems

We do not use AI tools that use your personal information to train public models and personal information will not be transferred outside the UK/EEA without appropriate safeguards and consent being in place.

You have several rights under data protection law. This helps you understand and control how your personal information is used.

• Right to be informed – You can ask us to explain how we collect, use, share, and store your personal information.
• Right of access – You can request a copy of the personal information we hold about you, along with details of how we use it.
• Right to rectification – If you think any of your information is wrong or incomplete, you can ask us to correct or update it.
• Right to erasure – In some situations, you can ask us to delete your personal information.
• Right to restrict processing – You can ask us to limit how we use your information in certain circumstances.
• Right to object – You can object to us using your personal information, for example for direct marketing.
• Right to data portability – You can ask us to send your personal information to you, or directly to another organisation, in a structured, commonly used electronic format.
• · Rights related to automated decision‑making and profiling – If a decision about you is made without human involvement, you can challenge it and ask for someone to review it.

We must have a valid legal reason (a lawful basis) for collecting and using your personal information. For the financial planning, services we provide, we rely on the following lawful bases:

Contractual obligations

This is the main reason we use your personal information. We need certain details from you so we can deliver the services we’ve agreed to provide.

Legal obligations

Sometimes the law requires us to collect and use specific information. For example, UK anti‑money‑laundering laws require us to verify your identity.

Consent

In some situations, we may need your explicit consent to use special category information (listed below). We will always explain why we need this information and ask for your clear agreement before using it.

Special category information (used only when relevant and only with your explicit consent)

• Health information (e.g. for insurance advice)
• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union membership
• Genetic information
• Biometric information used for identification (e.g. access or payment systems)
• Sex life information
• Sexual orientation information

We also ask for your consent if you would like to receive updates about products or services that may interest you.

If we rely on your consent, you can withdraw it at any time.

Legitimate interests

We may keep certain personal information because we have a legitimate business reason to do so, for example, to check the suitability of our services, respond to any complaints in the future, or to meet the requirements of our Professional Indemnity insurer.

We keep the personal information we need to provide our services to you, and we take reasonable steps to make sure it stays accurate and up to date. Some information must be kept minimum periods set by our regulator, the Financial Conduct Authority (FCA):

• Mortgage business – 3 years
• Insurance business – 3 years

We also have to keep Identity‑verification documents (required under UK anti‑money‑laundering rules) for:

• At least 5 years after our relationship with you ends
• Up to 10 years if we still have an ongoing relationship

Because these are legal requirements, we cannot delete your information before these time periods have passed.

We may keep your personal information for longer if we have a legitimate business reason to do so, however, we will not keep it for more than 5 years after our relationship with you ends.

You can ask us to delete your personal information.  We will do so unless we are required to keep it for legal or legitimate business reasons.

If you would like more information about how long we keep your personal information or how we decide this, please contact us.

We may need to collect personal information about your close family members and dependents to provide our service(s) effectively. If this is the case, you are responsible for ensuring you have their consent to share this information with us.

If you act as a trustee or attorney, we may also need information about the relevant beneficiaries or donor(s).

We will give them a copy of this privacy notice or ask you to pass it on if that’s more appropriate.

If you have any concerns about how we use your personal information, you can contact us using the details at the top of this privacy notice.

If you are not satisfied with our response, you can also complain to the ICO.

The ICO’s address:       

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

This privacy notice was last updated on 08/06/2026.