Data Privacy Notice

For individuals whose data we process on behalf of our clients.

Version 1 · Last updated · 17 July 2026

1. Who we are

This Data Privacy Notice explains how Adviser Technologies Limited, trading as Adviser.ai ("we", "us", "our"), processes your personal data as part of the service we provide to our clients.

This notice is made available to you because one of our clients has submitted your contact details to our platform in order to invite you to complete a fact find or to notify you of a relevant matter regarding their products or services, or because you have already used it.

We are registered with the Information Commissioner's Office (ICO) under registration number ZA474755.

Data ProcessorAdviser Technologies Limited t/as Adviser.ai Data ControllerThe client company on whose behalf we process your data DPOLuke Ashworth Email Phone020 8050 1295 AddressKemp House, 128 City Road, London, EC1V 2NX

2. Who controls your data

Our client, the company that has used our platform to contact you, is the data controller in respect of your personal data. This means they have determined the purposes and means by which your data is processed. We process your data strictly on their behalf and according to their instructions.

If you would like to know which of our clients submitted your data, or to contact them directly, please contact us and we will assist you.

3. Personal data we process

We may process the following categories of personal data about you:

Identity data: your first and last name;
Contact data: email address and mobile phone number;
Journey data: information you provide directly when using our online software, which may include financial circumstances, lifestyle information, and professional details relevant to the product or service being discussed;
Usage data: records of your interaction with our system, including whether you have accessed or completed any journey.

We will only collect special categories of personal data (such as health information) where it is strictly necessary to enable our client to provide you with appropriate guidance, and we will do so only with a lawful basis to do so.

4. How we use your personal data

We process your personal data for the following purposes, each of which is carried out on behalf of our client:

To send you an invitation (by SMS or email) to use our online software, on behalf of our client;
To facilitate your use of the software and to record any responses you provide;
To pass the information you have provided, along with your contact details, back to our client so that an adviser can follow up with you regarding their products or services;
To maintain a record that you have opted out of communications, where applicable, so that you are not contacted again by that client using our platform.

We do not use your personal data for our own marketing purposes and we will never sell your data.

5. Lawful basis for processing

We process your personal data on the following lawful bases, as determined by our client as data controller:

Legitimate interests: our client has a legitimate interest in contacting their existing customers to offer relevant products and services. We have assessed that this interest is not overridden by your rights and freedoms;
Consent: where our client has obtained your consent to receive marketing communications, we process your data on that basis;
Legal obligation: where we are required by law to retain or disclose data.

Where processing is based on consent, you have the right to withdraw that consent at any time (see Section 9 below).

6. How long we keep your data

We retain your personal data only as long as necessary:

If you have not used the software: your personally identifying data (name, email address and phone number) will be deleted no later than six months after it was uploaded to our system by our client;
If you have used the software: we will retain your full data for six months after the date you last used the system. After that, your name, email address and phone number will be anonymised. We may retain anonymised, aggregated data indefinitely to improve our services;
Opt-out records: if you have opted out of marketing, we will retain your email address and/or phone number indefinitely in order to honour your opt-out and ensure you are not contacted again.

7. Sharing your personal data

We will share your personal data only as follows:

With our client: we will pass back to our client any details you provide as part of the process, as well as your contact details, so that they can follow up with you appropriately;
With regulators and legal authorities: we may be required to disclose personal data to regulators, courts or other authorities if required by law;
With our technical service providers: limited technical staff at Adviser Technologies Limited may have access to your data strictly for development and customer service purposes, under confidentiality obligations;
HostPresto (UK): our hosting provider, whose servers store your personal data. HostPresto is based in the United Kingdom and your data remains in the UK at all times on their infrastructure.

We will never sell, share or otherwise transfer your personal data to any other third party.

8. Where your data is stored and international transfers

Your personal data is stored on secure servers located in the United Kingdom, hosted by HostPresto, a UK-based provider. Your data remains in the United Kingdom on HostPresto's infrastructure.

In order to deliver communications to you, specifically the SMS messages and emails through which you are invited to use our software, we use the following third-party service providers:

Twilio Inc.: used to send SMS messages to your mobile phone number. Twilio is headquartered in the United States. Twilio is certified under the UK Extension to the EU-US Data Privacy Framework and maintains Standard Contractual Clauses (SCCs) as an additional transfer mechanism, ensuring your personal data receives a level of protection equivalent to that provided under UK law. You can review their privacy policy at www.twilio.com/en-us/legal/privacy.
Twilio SendGrid (a subsidiary of Twilio Inc.): used to send emails to your email address. SendGrid is headquartered in the United States and relies on the same transfer safeguards as Twilio above. You can review their privacy policy at www.sendgrid.com/policies/privacy.
TextMagic Ltd: used to send SMS messages to your mobile phone number. TextMagic is headquartered in Estonia and operates within the European Economic Area (EEA). The United Kingdom has determined that EEA countries provide an adequate level of data protection, meaning that transfers to TextMagic do not require additional safeguards such as Standard Contractual Clauses. You can review their privacy policy at www.textmagic.com/privacy-policy.

9. Your rights

Under the UK GDPR, you have the following rights:

Right of access - to request a copy of the personal data we hold about you;
Right to rectification - to request correction of inaccurate or incomplete data;
Right to erasure - to request deletion of your personal data;
Right to restriction - to request that we limit our use of your data;
Right to data portability - to receive your data in a structured, machine-readable format where technically feasible;
Right to object - to object to processing based on legitimate interests;
Right to withdraw consent - where we process data based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

As we process your data on behalf of our client, we may need to refer some requests to them as the data controller. We will always acknowledge your request and inform you of the appropriate next steps. Where you have requested deletion or an opt-out, we will notify our client immediately.

You will not be charged a fee to exercise these rights unless your request is manifestly unfounded or excessive.

10. Automated decision-making

Our software may ask you through a series of questions to help our client's advisers understand your needs. This process does not result in solely automated decisions with legal or similarly significant effects. A human adviser at our client will review your responses before any follow-up contact is made.

11. How to opt out or stop being contacted

You may opt out of further contact at any time by:

Emailing us at ;
Calling us on 020 8050 1295;
Writing to us at Kemp House, 128 City Road, London, EC1V 2NX.

When you opt out, we will immediately notify our client and update our system to ensure that you are not contacted again by that client via our platform.

If you have already made a request for a call but also wish to opt out of future automated marketing, your data will remain available to the adviser handling your original request, but no further automated communications will be sent to you.

12. How to contact us and how to complain

If you have any questions about how your data is used, wish to exercise your rights, or have a concern, please contact our Data Protection Officer:

NameLuke Ashworth, Data Protection Officer Email Phone020 8050 1295 PostAdviser Technologies Limited t/as Adviser.ai, Kemp House, 128 City Road, London, EC1V 2NX

If you are not satisfied with our response, or if you believe we are processing your data in a way that is not compliant with the law, you have the right to lodge a complaint with the Information Commissioner's Office:

Websitewww.ico.org.uk Phone0303 123 1113 PostInformation Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Try it free* *Qualifying distributors only