Privacy Policy

Effective Date: 79th February 2026

This is the Privacy Policy for WTW Ltd, which explains how we use any personal information we collect about you.

The firm is registered with the Information Commissioners Office (ZA560679).

1. What information do we collect about you?

We collect information about you when you request us to provide you with a service and engage us for financial advice and investment management services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health and philosophical beleifes, if this is necessary for the provision of our services.

We try at all times to keep at all personal data collected and processed accurate and up-to-date. We check the accuracy of data when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken to amend or erase that data, as appropriate.

2. Information about connected individuals

We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy policy for them or, where appropriate, ask you to pass the privacy information to them.

3. Why do we need to collect and use your personal data?

The primary legal basis of processing will be for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.

Where special category data is required we’ll obtain your separate explicit consent in order to collect and process this information.

4. How will we use the information about you?

We collect information about you in order to provide you with our services.

We may use secure, business‑grade Artificial Intelligence (“AI”) tools to support certain administrative and operational tasks. These may include drafting communications, summarising documents, preparing internal notes, and, with your consent, recording and transcribing client meetings. Meeting recordings and any AI‑generated transcriptions are used solely for accuracy, record‑keeping, and to ensure the advice we provide reflects your circumstances.

We do not input personal or confidential information into AI systems unless those systems meet our security and data‑protection requirements, operate under appropriate contractual safeguards, and are accessed only through authorised business accounts. We never use public or consumer‑grade AI tools for any client processing.

All AI‑supported processes are subject to human oversight. AI is not used to make decisions about you or to generate financial, legal or regulatory advice without review by a qualified adviser.

We are fully committed to compliance with UK GDPR and the Data Protection Act 2018 and ensure any personal data processed through AI systems remains secure, lawful, and appropriately protected.

5. Who might we share your information with?

In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.

Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.

Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes and agreements are in place to protect your data in accordance with data protection laws and policies.

6. How long do we keep hold of your information?

During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.

We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:

• Five years for investment business;
• Indefinitely for pension transfers and opt-out business;
• Three years for insurance business;

These are minimum periods, during which we have a legal obligation to retain your records.

We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so.

You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our wider regulatory obligations and the lawful basis we use to process it.

7. How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.

You may make a subject access request (SAR) at any time to find out more about the personal data which we hold about you. We are usually required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).

All subject access requests must be sent to Martin Welsh, who is responsible for the firms Data Protection. Please write to Martin using the address noted in Section 12 below or the following email: martin@welshandtaylorwealth.co.uk

We do not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

You also may have the following rights in respect of your personal data:

• The right to be informed of the processing;
• The right to rectification;
• The right of erasure;
• The right to restrict processing;
• The right of data portability;
• The right to object to processing;
• The right to understand automated decision making and profiling.

For more details on how to exercise these rights please contact us.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

8. Marketing

We’d like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.

We may email you about other products or services that we think may be of interest to you, however we won’t share your information for marketing purposes with other companies.

You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.

9. Other websites

Our website contains links to other websites. This privacy policy only applies to our website so when you link to other websites you should read their own privacy policies.

10. What can you do if you are unhappy with how your personal data is processed?

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
0303 123 1113 (local rate)

11. Changes to our privacy policy

We keep our privacy policy under regular review and we’ll place any updates on our website and inform you of any changes when they occur. This privacy policy was last updated on 9th February 2026.

12. How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you by email at team@welshandtaylorwealth.co.uk

Or write to us at:

Welsh & Taylor Wealth, 2nd Floor, H1, Hill of Rubislaw, Anderson Drive, Aberdeen, AB15 6BL