Privacy Policy

A F S Financial Management Limited. Last updated: 9 November 2026

1. Who we are

This Privacy Policy explains how A F S Financial Management Limited (“AFS”, “we”, “us”, “our”) collects, uses and protects personal information. It covers visitors to our website, afsfinman.com, people who contact us, and our clients.

A F S Financial Management Limited is registered in England and Wales under company number 01554629. Our registered office is 40 Upper Montagu Street, London, W1H 1RP. We are authorised and regulated by the Financial Conduct Authority (FRN 485097).

We are the data controller for the personal information described in this policy, and we are registered with the Information Commissioner’s Office (ICO) under registration number ZA577975.

If you have any questions about this policy or how we handle your information, please contact us:

2. Information we collect

The information we collect depends on how you interact with us.

If you visit our website, we collect technical information such as your IP address, browser type, device type, pages viewed and how you arrived at the site. Some of this is collected using cookies, which are explained in our Cookies Policy.

If you contact us by email, telephone or through a form on our website, we collect the details you give us, such as your name, email address, telephone number and the content of your message.

If you subscribe to our updates, we collect your name and email address, and whether you open or click our emails.

If you become a client, we need more detailed information to provide financial advice and arrange financial products. This may include:

  • Identity and contact details, such as your name, date of birth, address, email, telephone number, National Insurance number and identification documents.

  • Personal and family circumstances, such as your marital status, dependants, employment and retirement plans.

  • Financial information, such as your income, expenditure, assets, liabilities, pensions, investments, tax position, bank details and attitude to investment risk.

  • Information about your objectives, such as your financial goals and future plans.

  • Records of our dealings with you, such as meeting notes, correspondence and recordings of telephone calls where we make them.

3. Special category information

In some cases, for example, when advising on protection, pensions or later-life planning, we may need information about your health, or other special category information. We will only collect and use this information where it is necessary for the advice or service you have asked for, and we will ask for your explicit consent where the law requires it.

If you give us information about other people, such as your partner, dependants or beneficiaries, please make sure they are aware and are happy for you to share it.

4. Where we get your information

Most of the information we hold comes directly from you. We may also receive information from:

  • product providers, investment platforms and pension schemes you hold or are considering

  • your other professional advisers, such as accountants or solicitors, with your agreement

  • identity verification and anti-money laundering services

  • publicly available sources, such as Companies House and the electoral register

5. How we use your information and our lawful bases

Data protection law requires us to have a lawful basis for each way we use personal information. We rely on the following:

  • Responding to your enquiry: our legitimate interests in responding to people who contact us, or taking steps at your request before entering into a contract.

  • Providing financial advice and arranging products: performance of our contract with you.

  • Verifying your identity and preventing financial crime: legal obligation (anti-money laundering regulations).

  • Keeping records required by our regulator: legal obligation (FCA rules).

  • Handling complaints: legal obligation and our legitimate interests.

  • Using health or other special category information for advice: your explicit consent, or where necessary for insurance purposes as permitted by law.

  • Sending updates and articles by email: your consent, or our legitimate interests for existing clients (you can opt out at any time).

  • Running, securing and improving our website: our legitimate interests in operating a secure, effective website.

  • Website analytics cookies: your consent.

Where we rely on legitimate interests, we have considered your rights and interests and are satisfied they are not overridden. Where we rely on consent, you can withdraw it at any time by contacting us, although this will not affect anything we have done before you withdraw it.

We do not sell your personal information, and we do not make decisions about you based solely on automated processing.

6. Who we share your information with

We share personal information only when we need to, and with organisations required to protect it. Depending on the service we provide, this may include:

  • product providers, investment platforms, pension schemes and insurers, to arrange and manage products for you

  • compliance support providers, who may review our advice files to check they meet regulatory standards

  • paraplanning or administrative support providers, where we use them

  • identity verification and anti-money laundering service providers

  • other professional advisers, such as your accountant or solicitor, where you ask us to

  • our IT, website, email and document storage providers, who process information on our behalf

  • our professional advisers, auditors and insurers

  • regulators and authorities, including the Financial Conduct Authority, the Financial Ombudsman Service, HM Revenue & Customs and law enforcement agencies, where we are legally required to

If AFS were sold or merged with another firm, client information could be transferred to the new owner, who would be bound by data protection law in the same way.

7. International transfers

Some of our service providers, including our website platform (Squarespace) and email hosting providers, may store or process information outside the UK. When this happens, we ensure appropriate safeguards are in place, such as UK adequacy regulations, the UK Extension to the EU–US Data Privacy Framework, or the UK’s International Data Transfer Agreement or Addendum.

8. How long we keep your information

We keep personal information only for as long as we need it for the purposes described in this policy, including to meet our legal and regulatory obligations.

  • We keep client records for at least five years after our relationship ends, as required by FCA rules. For some types of advice, such as pension transfers, regulatory requirements mean we must keep records indefinitely.

  • We keep anti-money laundering records for at least five years after our relationship ends, as required by law.

  • We keep email subscribers on our list until they unsubscribe.

When we no longer need information, we securely delete or destroy it.

9. How we protect your information

We use appropriate technical and organisational measures to protect personal information from loss, misuse and unauthorised access. These include encrypted data storage, secure data transfer and staff training. No method of transmission over the internet is completely secure, so please avoid sending sensitive financial information through our website contact form.

10. Your rights

Under UK data protection law, you have the right to:

  • access the personal information we hold about you

  • correct information that is inaccurate or incomplete

  • erase your information, where there is no overriding reason for us to keep it

  • restrict how we use your information in certain circumstances

  • object to our use of your information where we rely on legitimate interests, including for direct marketing

  • data portability, to receive your information in a reusable format where we process it by consent or contract

  • withdraw consent at any time, where we rely on consent

Some rights are limited where we must keep information to meet legal or regulatory requirements. To exercise any of these rights, please contact us using the details in section 1. We will respond within one month, and there is usually no charge.

11. Complaints

If you are unhappy with how we have handled your personal information, please contact us first so we can try to put things right. You also have the right to complain to the Information Commissioner’s Office:

12. Links to other websites

Our website may link to other websites, such as product providers or government sites. We are not responsible for how those sites handle personal information, so please read their privacy policies.

13. Changes to this policy

We may update this policy from time to time. The latest version will always be on this page, with the last updated date shown at the top.