Who we are.
At True Potential, we take the privacy and security of your personal data very seriously. In this notice, “we,” “us” or “our” means the True Potential Group which is made up of the following legal entities:
- True Potential Group Limited (a private limited company registered in England and Wales under company number 09917444, whose registered office is at Newburn House, Newburn Riverside, Newcastle Upon Tyne, NE15 8NX).
- True Potential Administration LLP (a limited liability partnership registered in England and Wales under company number OC426081, whose registered office is at Newburn House, Newburn Riverside, Newcastle Upon Tyne, NE15 8NX).
- True Potential Investments LLP (a limited liability partnership registered in England and Wales under company number OC356027, whose registered office is at Newburn House, Newburn Riverside, Newcastle Upon Tyne, NE15 8NX).
- True Potential Wealth Management LLP (a limited liability partnership registered in England and Wales under company number OC356611, whose registered office is at Newburn House, Newburn Riverside, Newcastle Upon Tyne, NE15 8NX).
- True Potential Adviser Services LLP (a limited liability partnership registered in England and Wales under company number OC326607, whose registered office is at Newburn House, Newburn Riverside, Newcastle Upon Tyne, NE15 8NX).
- True Potential Trustee Company Limited (a private limited company registered in England and Wales under company number 08388342, whose registered office is at Newburn House, Newburn Riverside, Newcastle Upon Tyne, NE15 8NX).
We act as a data controller for some processing activities e.g. we decide how and why your personal data is collected and handled on our investments and wealth management platforms but we are also a data processor for other activities e.g. we act on the instruction of Directly Authorised firms who use our digital platform to manage their clients.
All our entities are registered with the Information Commissioner’s Office (ICO) for various processing activities covered under Article 30 of the UK-GDPR.
What personal data we may hold on you
Below are types of personal data we may hold about you depending on how it was collected.
Information provided by you.
You may give us your personal data when you engage with us by phone, email, in writing or otherwise. Here are some examples of when your personal data will be collected and then held by us. When you:
- apply for our products and services
- correspond with us such as talk to us on the phone or by other means
- open an investment account
- register for email alerts
- request literature
- sign-up for newsletters or enter a competition, promotion, or survey
- use our websites, mobile device apps, web chat or other services
- respond to financial reviews and interviews in customer surveys
The information you give us may include your name, address, email address and other contact information, financial information, (including existing investments, funds held with banks and other financial institutions), information regarding financial debts, (mortgages, loans, credit cards) and debit card information.
Information collected from you.
When you visit our sites or use our services, we may automatically collect the following information.
- technical information, including information obtained by cookies and similar technologies, your Internet Protocol (IP) address used to connect your computer to the internet, your login information, your geographic location, browser type and version, browser plug-in types and versions, operating system and platform used.
- analytical information, including information about your website visit, such as the source of your visit, the full click path, mouse movement through our sites (including date and time); services you viewed, searches made on our sites, page response times, download errors, length of visits to certain pages, page interaction information (such as page scrolling, mouse clicks, mouse movements and keyed text), and methods used to browse away from the page and any phone number used to call our Helpdesk. This information may be collected using a website recording service.
- tracking information including the receipt and opening of emails, your geographic location, browser type and version, device type and operating system and platform, how you have accessed/used the e-mail, including the full click path from within and on to our sites (including date and time), whether the email was unsubscribed from, opened, deleted, forwarded or printed, and how long the email was open.
Information received from third parties.
As well as sharing information between entities within our Group we may also receive information about you from third party service providers. The type of third parties we work with include:
- Introducers
- Insurers
- Comparison websites
- Fraud prevention agencies
- Credit reference agencies
- Payroll service providers (In relation to Auto-Enrolment Pension products)
- Public information sources such as Companies House
- Agents working on our behalf
- Market researchers
- Regulatory bodies
- Government, law enforcement or judicial agencies
This information could be used as part of the service we provide to you, or as part of our regulatory or legal obligations. We may combine this information with information you give to us and information we collect about you.
How we protect your personal data
Keeping your personal data safe is very important to us so we will take all steps necessary to ensure that your personal data is treated securely and in accordance with this Privacy Notice and applicable data protection legislation.
To help protect your personal data and minimise the risk of it being intercepted by unauthorised third parties, our secure servers employ Secure Socket Layer v3 (SSL) or Transport Layer Security v1 (TLS) encryption when you submit information to us through our sites. This security is signified by the “https” and the padlock on the URL bar. Some older browsers do not allow the use of current SSL technology and we, therefore, recommend that you use an up-to-date browser.
Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access.
Justifying the use of your personal data
We have considered the use of your personal data and have justified it based on one of the six options available under data protection law. If we use any special category or sensitive personal data, we will invoke an additional condition under Article 9 of the UK-GDPR or Schedule 1 of the Data Protection Act 2018. See below on what we use your personal data for and the basis upon which we justify it.
| Activity |
Justification |
Legal basis |
| Service provision |
To fulfil our contractual obligations |
Contract |
| Customer care |
To comply with any instructions you give to us |
Contract |
| Change management |
To notify you about changes to our service |
Contract |
| Promotion and deliver news content |
To provide you with information by post, email, telephone or otherwise about products and services of a similar nature to those you have previously purchased or expressed an interest in which are offered by our Group and which we think may be of interest to you |
Legitimate Interests |
| Website and digital platform management |
To administer our sites and for internal operations, including troubleshooting, data analysis, load management, testing, research, statistical and survey purposes |
Legitimate interests |
| Digital customer experience |
To improve our sites to ensure that content is presented in the most effective manner for you and for your device, measure or understand the effectiveness of content/service we serve to you and others, deliver relevant content/products to you and providing services such as ‘most popular’ information on our site |
Legitimate interests |
| Solicit feedback |
To obtain your feedback on a product, service, or our sites via a third party appointed by us |
Legitimate interests |
| Product development |
To perform customer modelling, statistical and trend analysis, with the aim of developing and improving our products and services |
Legitimate interests |
| Sales |
To pursue of our commercial activities and objectives, or those of a third party |
Legitimate interest |
| Operational optimisation |
To improve and develop our business operations and service offering, or those of a third party |
Legitimate interest |
| Safeguarding |
To protect our business, shareholders, employees, and clients, or those of a third party |
Legitimate interest |
| Detect and prevent crime and civil offenses |
To verify identity and indebtedness before we provide products or services to you or your business and to help detect fraud and money-laundering risks |
Legitimate interest |
| Compliance |
To comply with applicable legal and regulatory obligations and any codes of conduct |
Legal requirement |
| Direct marketing |
To promote our products and services e.g. by delivering targeted advertisements to you by assessing your needs and optimising the relevance of our products and services you see as you move through ourdigital journey |
Consent |
Who we share your personal data with
Whilst we may share the personal data we hold about you with entities within the True Potential Group, we may also share your personal data with the following types of third parties to enable us to better understand your needs and run your accounts efficiently and in line with your expectations.
Partners, suppliers, and sub-contractors including:
- Companies within the True Potential Group who offer advice
- Companies who provide investment trading and/or custody services
- Companies who provide payment/transaction services
- Companies with who we use to provide us with advice and accountancy services
- Our shareholders
Governmental or judicial bodies or agencies including:
- HM Revenue & Customs
- Financial Conduct Authority
- The Pensions Regulator
- UK Financial Services Compensation Scheme
- Financial Ombudsman Service and other regulatory bodies and authorities
Fraud and anti-money laundering prevention agencies, other companies, and organisations to prevent or detect financial and other crime including:
- National Crime Agency (NCA)
- Service providers who offer Anti-Money Laundering and Fraud Screening services
- Fraud Prevention Agencies (FPAs)
- Credit reference agencies for the purpose of client banking identification
- Law enforcement agencies to support their duty to detect, investigate, prevent crime
- Judicial authorities whose duty it is to prosecute crime
Advertisers including:
- Advertising networks that require your personal data to select and serve adverts about our services to you
- Data, service, and software providers that assist us in the improvement and optimisation of our sites and any party linked with you or your business’s product or service
Introducers including:
- Companies with whom we have a joint venture or agreement to introduce you to us such as solicitors, accountants, financial institutions and so on
Other third parties including:
- Companies you ask us to share your personal data with
We may also share your personal information with third parties if the make-up of the True Potential Group changes in the future. For example:
- if we sell or buy any business or assets, we will pass your personal data to the prospective seller or buyer of such business or assets
- if we or all our assets are bought by a third-party, your personal data held by us will be one of the transferred assets; and
- if there are changes to our Group (such as a Group reorganisation), then other parties may use your personal data in the same way as set out in this notice
Transferring your personal data abroad
We do all we can to keep your personal data inside the UK or only to transfer i.e. send, store or allow access to your personal data to a country that has been deemed as having a similar level of protection around personal data like the UK as deemed by the UK Government.
If we do need to transfer your personal data beyond these countries, we will make sure that it is protected as if it were in the UK by undertaking a Transfer Risk Assessment (TRA) and using an appropriate safeguard such as:
- The UK’s International Data Transfer Agreement
- The EU’s Standard Contractual Clauses (SCCs) with UK addendum attached
- Using US based companies signed up to the Data Privacy Framework (DPF)
- Our own contracts
- Derogations permitted by the UK-GDPR
How long we keep your personal data
We will keep your personal data for as long as you are a client of True Potential.
After you stop being a client, we may keep your personal data for a period of time. This will be based on:
- A legal requirement with which we are obliged to comply
- A regulatory requirement to which we must adhere
- Industry practice we follow
- A strong business case
For any pension products you may hold, we are required to retain data relating to these indefinitely i.e. until the pension scheme itself is wound up.
We may keep your personal data for longer than the period of time than the above justifications we have documented if we cannot delete it for legal or regulatory reasons. If we do, we will make sure that your privacy is protected and only use your personal data for those purposes.
How our website works
Links to external websites
Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. We will only ever support links to reputable companies who maintain the highest standards of data security in line with the UK -GDPR.
If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or how such websites collect and use your personal data. Please check these policies before you submit any personal data to these websites.
Social media widgets and applications.
Our sites may include functionality to enable sharing via third party social media applications, such as the Facebook Share button and X widget. These social media applications may collect and use information regarding your use of our sites (see details on cookies).
Any personal data that you provide via such social media applications may be collected and used by that social media application and such interactions are governed by the privacy notices of the companies that provide the application. In the majority of cases, we do not have control over, or responsibility for, those companies or their use of your personal data.
Cookies, analytics, and web beacons
Our sites use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our sites and allows us to improve our sites.
When we send you an email, we may track whether you have opened that email and whether you have clicked any links it may contain. This helps us measure the performance of our email campaigns. We do this by including single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you opened an email, your IP address, your browser or email client type, and other similar details.
Cookies are used on almost every website. They are small text files that are saved on your computer to help the site perform a number of functions. Here is why we use them:
| Security |
To provide securely our services so you can access your account, place a deal, or open a new account |
| Ease of use |
To remember your login information to help you access your account easily if you request this. Please do not ask us to remember your login information if you are on a public computer |
| Monitor visitor numbers and activity |
To monitor the number of people using our website and collectively monitor their activities. |
| Understand how people get to our site |
To see how you arrive at our site (e.g. search for ‘True Potential’ on a search engine, or click on an email we have sent) |
| Understand more about the types of people visiting our site |
To gather a little technical information about you use our site, such as your geographic location (to city level) and the type of web browsers you are using |
| Deliver relevant content |
To display adverts on other websites to you if you have previously accessed the True Potential website. |
| Tailor your experience |
Remember your settings and preferences to make using the True Potential site easier. |
We use several types of Cookies including:
- Session cookies that are stored on your computer and remain available for the duration of your visit to our site. When you close your browser, any session cookies that have been set will be automatically removed from your computer’s memory.
- Persistent cookies are stored on your computer and remain there until they reach their expiration date, or you choose to delete them. At this point, the browser will delete the cookie from your computer’s hard drive. While the persistent cookie is present, the website that created it will have access to that cookie each time you return to that particular site.
We make use of both types of cookies to maximise the security of our services and to ensure you always get an optimal service from our site.
We do not use cookies to track your use of the internet after leaving our website, nor do we store any information about you in cookies that others could read and understand.
First and Third-Party Cookies refer to the website/service placing the cookie. First-party cookies are those set by us. Third-party cookies are cookies that are authorised by us but provided via one of our suppliers. In some limited cases, we may use our suppliers to manage some of these cookies for us, but we never allow any third party to use these cookies for their own purposes.
We use a system of classification for our cookies developed by the International Chamber of Commerce. This allows us to classify the different types of cookies that we use on our website to provide you with more information about why we use them.
Strictly necessary cookies are cookies that are essential to provide specific services you have requested from us. These help us to:
- Remember information you have entered on online application forms when you navigate to different pages in a single web browsing session.
- Maintain a logged-in session on our website.
Performance cookies aim to improve our website by collecting information about how you use our website. These help us to:
- Count the number of visitors and how they move around our site.
- Understand what interests our users so that we can deliver the content and level of service you expect from us.
- Help us to improve our site by measuring errors experienced by users of our site.
- Assess different designs or content on our site.
Functionality cookies will typically be set because of an action you have taken on our website but may also be set in the delivery of other services. These helps us to:
- Save your preferences when using interactive share charts.
- Collect information about your browsing in order to deliver promotions relevant to you and your interests. We may, from time to time, use this type of cookie on our site to deliver promotions relevant to you.
Promotional cookies may also be used to limit the number of times you see a promotion as well as help measure the effectiveness of the promotion.
Analytical cookies, supplied by Google Inc, help us to analyse how users use this website. The information generated by the cookie about your use of our site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our site, compiling reports on website activity for website operators like us and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
You may refuse the use of our cookies by selecting the appropriate settings on your browser but please note that if you do this you may not be able to use the full functionality of our site. Most web browsers allow you to manage cookies via the browser settings. For example, you may choose to delete existing cookies, prevent your browser from accepting new cookies, have the browser notify you when you receive a new cookie or disable cookies altogether.
By using this website, you consent to the processing of data about you by us and Google in the manner and for the purposes set out above.
How we handle data protection rights
The UK-GDPR provides the following rights for individuals:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
Wherever possible we have created systems and processes for you to exercise these rights as easily as possible. For example, we have privacy notices and consent statements to help keep you informed about how your personal data will be handled and protected throughout our digital and in-person client journeys. You can also change your personal data through our website, app, call centre or your adviser.
Should you need to:
- access your personal data to understand or obtain a copy of the personal data we hold about you.
- request erasure of your personal data
- object to its handling or challenge its accuracy…
…you only need to contact us via the methods in this privacy notice set out under “How to contact us.”
We do not carry out any auto-decision making process about you because there is a human involved in all our digital processes.
Wherever your personal data is created to make a profile, such as when you visit our website so that we can target you with adverts, we have implemented safeguards such as obtaining your consent or allowing you to exercise your data protection rights to object to, appeal against or alter the personal data we hold on you.
If we need to change the reasons for the handling of your personal data, we have systems in place to obtain expert advice from our Data Protection Officer (DPO) and consider the risks and controls we need to ensure that the handling remains transparent, secure and of good quality.
How to withdraw your consent
You can withdraw any consent you have given us for the processing of your personal data at any time. Please contact us on the details below if you want to do so. Please note that if you do withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.
How to complain about how we handle or protect your personal data
We would always prefer you to give us the opportunity to see if we can handle your complaint in the first instance. You can contact us using the details below. However, you have the right to complain to the Information Commissioner’s Office (ICO) where you think we have not used your personal data in accordance with data protection law. Details of how to do this can be found on www.ico.org.uk.
How you can contact us about data protection matters
If you have any queries regarding privacy issues, you can email us at dataprotection@tpllp.com, or write to us at:
True Potential LLP
Newburn House
Gateway West
Newburn Riverside
Newcastle Upon Tyne
United Kingdom
NE15 8NX
Alternatively, you can call us on 0191 500 9164.
Mandatory provision of personal data
We may need to collect personal information by law, or under the terms of a contract we have with you.
If you choose not to give us this personal data, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a product or service you have with us.
Changes to our privacy notice
We reserve the right to revise or supplement this Privacy Notice from time to time. We will place updates on our sites, inform you of the updates and where appropriate we will give you reasonable notice of any changes.
