Customer Privacy Notice

CSense Financial Services
Privacy Notice v1.5
Effective 25 September 2026

Why should you read this document?

During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

CSense Financial Services is a trading name of CSense Capital FS Ltd. We are the data controller responsible for your information. This notice also covers initial enquiries, agreed ongoing services and referrals.

What do we mean by “Your Personal Data”?

Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date of birth, national insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

In the context of providing you with assistance in relation to your investment, pension, mortgage, finance and insurance requirements Your Personal Data may include:

Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
Any pre-existing investment, pension, mortgage, finance and insurance products and the terms and conditions relating to these

The basis upon which our firm will deal with Your Personal Data

When we speak with you about your investment, pension, mortgage, finance or insurance requirements, we use Your Personal Data to take steps at your request before entering a contract, and to provide the services you agree with us. This includes ongoing reviews where you have selected that service.

In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end, we may use Your Personal Data where we have a legitimate business interest, balanced against your rights. For example, we may need to respond to requests from lenders, providers and our compliance advisers relating to our advice, handle complaints or legal claims, or seek feedback on our service.

On occasion, we will use Your Personal Data to comply with legal or regulatory obligations, including requirements of the Financial Conduct Authority and identity checks. Where we rely on your consent, we ask for it separately and you can withdraw it by contacting us. Receiving this notice does not mean you consent to every use of your information.

The basis upon which we will process certain parts of Your Personal Data

Where you ask us to assist with insurance or other financial planning, we may need information about your health, medical history or other sensitive personal circumstances (Your Special Data). We only ask for information relevant to your needs, for example to advise on suitable protection or provide additional support.

We may also record relevant information about your children or other dependants where needed for your planning.

The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.

We give Your Special Data additional protection. Where your explicit consent is needed, we will ask for it separately. Otherwise, we will only use it where the law permits. Information about criminal convictions or offences is also subject to additional legal safeguards.

Where necessary and legally permitted, we share relevant sensitive information with insurers and other providers to obtain terms, arrange suitable products or support your service.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to investment, pension, mortgage, finance and insurance. You will provide information to us verbally and in writing, including email.

We may also obtain information from third parties, for example providers, lenders, your employer, professional advisers, credit-checking services and public registers. We explain relevant identity and credit checks, including whether a search may affect your credit record, and obtain permission where required. Electronic identity checks needed to meet legal obligations do not generally require consent, but we explain their purpose.

If you do not provide information needed by law or to deliver our service, we may be unable to advise you or arrange a product.

What happens to Your Personal Data when it is disclosed to us?

In the course of handling Your Personal Data, we will:

Record and store Your Personal Data in our paper files, mobile devices and computer systems, including email and cloud facilities. We use Google Workspace for email, documents and meetings. Authorised employees, consultants and service providers may access this information where necessary to provide our services and associated administration.
Submit Your Personal Data to product providers, platforms, mortgage and commercial lenders, and insurers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise. Where you are making an application for credit, the lender may refer to a credit reference agency who will process your data. This may impact upon your credit rating
Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investment, pension, mortgage or finance product, or insurance policy you may take out, or to inform you of any developments in relation to those products and/or policies of which we might become aware.

Artificial Intelligence (AI)

We use Google Gemini within our business Google Workspace account to support meeting notes, summaries and correspondence. We also use financial planning software, including Timeline, to support our advice.

To enhance the quality, efficiency, and accuracy of our services, we use AI to assist with:

Transcribing meetings and, where appropriate, recording them. We tell you before recording or transcription starts. You can decline either, and we will discuss an alternative such as written notes.
Generating meeting notes and summaries
Drafting correspondence and documentation
Conducting checks for compliance with internal procedures

Your adviser checks material facts before relying on AI outputs, and we confirm agreed matters with you in writing. AI supports our work; CSense remains responsible for our advice. If you have questions or concerns about these tools, please contact us.

Sharing Your Personal Data

From time to time Your Personal Data will be shared with:

Investment and pension providers, platforms, investment managers, mortgage and finance lenders, and insurers.
Third parties who support your enquiry, application or our services, including compliance advisers, product specialists, professional indemnity insurers, auditors, solicitors, accountants, estate planners, conveyancers, surveyors and valuers, where relevant. We also use providers of client portals, identity checks, IT, cloud storage, communications, planning and AI tools. Information may be provided to regulators, the Financial Ombudsman Service and other authorities where required or permitted by law.

In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress your investment, pension, mortgage, finance and insurance enquiry and to provide you with our professional services.

Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages, it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
Some service providers may store or access Your Personal Data outside the UK. Where a restricted international transfer is involved, we use a permitted arrangement, such as UK adequacy regulations or approved contractual safeguards. Contact us for details of the safeguards applying to your information and how to obtain a copy.

Security and retention of Your Personal Data

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

Please take reasonable steps to protect your information when sending it to us. Use the secure methods we provide for sensitive documents and tell us promptly if you think information has been sent to the wrong person or an account has been compromised.

We normally retain core advice and service records for at least six years after completing a one-off service or after our ongoing relationship ends. We may keep necessary records longer to meet legal or regulatory requirements. Certain pension advice records must be kept indefinitely. We review information and delete it when no longer needed.

Original transcripts, checked summaries and client confirmations may form part of your advice file. Audio created only for transcription is normally deleted shortly after transcription and an accuracy check, unless it must be preserved. Enquiry records and working copies are kept only while needed. If you ask for deletion, we explain any information we need to retain and why.

Your rights in relation to Your Personal Data

You can:

request copies of Your Personal Data that is under our control
ask us to further explain how we use Your Personal Data
ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
ask us to send an electronic copy of Your Personal Data to another organisation should you wish
withdraw consent where we rely on it, including your marketing consent, without affecting earlier lawful processing

You can also object to processing based on legitimate interests. We will consider your reasons and stop unless we have compelling grounds to continue or need the information for legal claims. You can always object to direct marketing, and we will stop that use.

Collection of data from a third party to support you

Where we receive information from a family member, trusted friend, attorney or other authorised person, we use it to support your advice or service for the purposes explained in this notice. We check their authority where appropriate. If you provide another person’s information, please let them know and share this notice with them.

How to make contact with our Firm in relation to the use of Your Personal Data

If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:

Principal Adviser, CSense Capital FS Ltd trading as CSense Financial Services, 94 Chertsey Road, Chobham, Surrey, GU24 8PJ. Email: admin@csensefs.com. Telephone: 01276 858180.

If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have a complaint about how we have handled Your Personal Data, you should contact us using the contact details above. We will carry out an investigation and respond to you with the outcome.

You can also complain directly to the Information Commissioner’s Office (ICO), the UK data protection regulator, at ico.org.uk or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. You do not have to wait for our response before contacting the ICO.

Marketing Consent

We obtain your marketing consent separately through our fact-find, client portal or another clear request. You can choose whether to receive marketing by telephone, text message, email or post. This includes offers of additional CSense services to existing clients. We follow your recorded choices for the relevant purpose and channel. You can withdraw consent at any time by contacting us or using an unsubscribe option. Marketing consent is optional and does not affect your access to our services.

We may still send necessary messages about your agreed service. We keep a limited record of marketing preferences so that we can honour them.