Your data, respected.

This privacy notice tells you how Evergreen Private Wealth collects, uses and protects your personal information. Evergreen Private Wealth is a trading name of Webb Wealth Management Limited, which is authorised and regulated by the Financial Conduct Authority, Firm Reference Number 197107. Webb Wealth Management Limited is registered in England & Wales, Company Number 13524471. Registered address: 9a Leicester Road, Blaby, Leicestershire, LE8 4GR

Who is the data controller?

For personal data collected through this website and during our relationship as your financial planner, Webb Wealth Management Ltd is the data controller. ValidPath Ltd may also act as a joint controller for regulated activities. You can contact us about your data at hello@evergreenprivatewealth.co.uk or by post at Gibson House, Ermine Business Park, Huntingdon, Cambridgeshire, PE29 6XU.

What personal data we collect

• Identification & contact details (name, address, phone, email, date of birth).
• Financial information (income, assets, liabilities, pensions, investments, employment).
• Family and dependant information where relevant to your plan.
• Health information where it is needed to advise on protection or annuity products.
• Records of our communications (emails, meeting notes, recorded calls where flagged).
• Technical data when you visit this website (see the Cookie Policy).

How we collect it

Directly from you when you contact us, complete a fact-find, or attend a meeting. Indirectly from your existing providers (pensions, investments, employers, accountants, solicitors) with your authority. From regulatory and public sources where needed (e.g. anti-money-laundering checks, FCA register lookups).

Lawful basis for processing

We rely on the following lawful bases under UK GDPR Article 6:

• Performance of a contract — to deliver the financial planning service you have asked us to provide.
• Legal obligation — to meet FCA, HMRC, money- laundering and other statutory requirements.
• Legitimate interests — to operate the practice efficiently, improve our service, and protect against fraud.
• Consent — where you have given explicit permission (e.g. marketing communications, optional cookies).

Where we process special category data (health, ethnicity, etc.), we rely on UK GDPR Article 9 — typically your explicit consent or substantial public interest under the Data Protection Act 2018.

How we use your data

• To research, recommend and implement financial plans.
• To monitor your portfolio and conduct periodic reviews.
• To carry out anti-money-laundering, sanctions and fraud checks.
• To respond to enquiries and book meetings (including via Cal.com).
• To meet our regulatory record-keeping obligations.
• To improve the website and understand visitor patterns (analytics, only with consent).

Who we share it with

• ValidPath Ltd, our regulatory principal, for compliance oversight and file checks.
• Product providers (pension, investment, protection, mortgage) when implementing a recommendation on your behalf.
• Professional connections (accountants, solicitors) where you have asked us to coordinate with them.
• HMRC, the FCA, the Financial Ombudsman Service or other regulators where required by law.
• Carefully selected service providers (IT, secure document storage, planning software) under written contracts that protect your data.

We do not sell your personal data and we do not share it for marketing purposes outside of our practice.

International transfers

Our suppliers are predominantly UK-based. Where data is transferred outside the UK (for example to a US-based analytics, content or email provider such as Sanity or Resend), we rely on UK-approved transfer mechanisms — Standard Contractual Clauses with an International Data Transfer Addendum, or an adequacy decision — and apply additional safeguards.

Free guides and marketing

When you request one of our free guides, we collect your first name, email address and phone number, together with the guide you requested and a record of the consent wording you were shown. We use these details to email you the guide. We will only contact you afterwards by email or phone if you ticked the separate box agreeing to that; if you did not, you will receive the guide and nothing more.

The lawful basis for this processing is your consent under UK GDPR Article 6(1)(a), and you can withdraw it at any time by emailing hello@evergreenprivatewealth.co.uk. Withdrawal does not affect processing that took place before you withdrew. Guide request details are stored securely with our content platform (Sanity) and guide emails are sent through our email provider (Resend), both under written contracts that protect your data. If you do not become a client, we keep your guide request details for no more than two years from your last interaction with us, after which they are deleted.

How long we keep it

We retain client records for as long as we are required to under FCA rules — typically six years after the end of our relationship, and longer where pension transfer advice is involved (indefinite for defined-benefit transfer recommendations). Marketing data is retained until you ask us to delete it.

Your rights

Under UK GDPR you have the right to: access your data, request correction, request erasure (where applicable), restrict processing, portability, and to object to processing. Where we rely on consent, you have the right to withdraw that consent at any time. To exercise any of these rights, contact us at hello@evergreenprivatewealth.co.uk.

How to complain

If you have a concern about how we handle your data, please raise it with us first. You also have the right to complain to the Information Commissioner’s Office: ico.org.uk / 0303 123 1113.

Changes to this policy

We may update this notice from time to time. The “last updated” date at the top reflects the most recent change.