Privacy Policy and Referral Disclosure

Life Bound Group Ltd is a United Kingdom-based marketing and lead-generation agency.

We are committed to protecting your privacy and handling personal information lawfully, fairly, transparently and securely.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you:

• Visit our website or marketing landing pages.
• Contact us about our services.
• Respond to one of our advertising campaigns.
• Submit a financial services enquiry.
• Request contact with a financial adviser.
• Communicate with us about an existing enquiry or introduction.

It also explains our role as a marketing agency, our commercial relationships with financial services providers, and your rights under applicable data protection legislation.

We process personal information in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, as amended, and the Privacy and Electronic Communications Regulations (PECR), where applicable.

Other data protection requirements, including the EU GDPR, may apply to particular international activities.

Business name: Life Bound Group

Legal entity: Life Bound Group Ltd, a private limited company registered in England and Wales (company number 17503977)

Business address: 66 Paul Street, London, EC2A 4NA, United Kingdom

Email: info@lifeboundgroup.co.uk

Life Bound Group acts as a data controller where we determine the purposes and means of processing personal information.

This includes enquiries and lead-generation activities that we independently manage, our business relationships, marketing qualification and introductions arranged by us.

We use GoHighLevel to collect, organise and manage prospective customer information.

Where an individual agrees to an introduction, we may share relevant information with one identified financial adviser.

The receiving adviser will normally act as a separate data controller when processing that information for its own advisory services, communications and client relationships.

Where we process personal information solely on the documented instructions of another organisation, we may act as its data processor instead. Any applicable alternative controller arrangements will be explained through the relevant campaign information.

ICO registration: Life Bound Group Ltd maintains its applicable data protection fee registration with the Information Commissioner's Office, and its fee is up to date.

Life Bound Group provides advertising, marketing, lead-generation and introductory services to businesses, including financial advisers authorised by the Financial Conduct Authority (FCA).

Life Bound Group is not FCA-authorised and is not an appointed representative of an FCA-authorised firm.

We do not provide regulated financial advice, make personal financial recommendations, assess the suitability of financial products or undertake regulated product arrangements.

Our role is to generate enquiries from individuals interested in financial services and, where appropriate and agreed, facilitate introductions to relevant advisers.

We may assess whether an enquiry meets general marketing or introductory criteria, including:

• General service interests.
• Location.
• Contact preferences.
• Information voluntarily supplied through introductory questions.
• Whether an individual wishes to speak with an adviser.

Marketing qualification is not a financial suitability assessment, affordability assessment, investment recommendation or determination of eligibility for a financial product.

Any regulated advice, product recommendation, suitability assessment or regulated arrangement must be undertaken by a provider with the necessary legal permissions.

Financial promotions

Certain financial services advertisements and communications are subject to restrictions under the Financial Services and Markets Act 2000 and applicable FCA rules.

Where a campaign constitutes a regulated financial promotion, it must be communicated lawfully, including through any necessary approval by a person with the appropriate permission or under a valid exemption.

Life Bound Group does not claim independent authority to approve regulated financial promotions.

Our involvement in creating, managing or distributing advertising does not remove any regulatory obligations applicable to us or the financial services provider.

Depending on your interaction with us, we may collect the following categories of personal information.

Contact information

Your name, email address, telephone number, general location and preferred method of contact.

Financial services enquiry information

The general type of financial service you are interested in, relevant information voluntarily provided through an enquiry form, introductory responses and appointment preferences.

Communication information

Records of enquiries, correspondence, appointment arrangements, consent choices, communication preferences, objections and withdrawal requests.

Business information

Business names, professional contact details, service enquiries, contractual correspondence and relevant billing information.

Technical information

Limited technical information processed through our website, forms or service providers, which may include IP addresses, browser information, security logs and information necessary for website functionality.

We aim to collect only information reasonably necessary for the relevant purpose.

We do not intentionally request passwords, full bank or payment card details, identity documents or sensitive medical information through general marketing forms.

Information required for regulated financial advice should be provided directly to the relevant adviser through appropriate channels.

We do not intentionally collect special-category personal data through general marketing enquiries. Where such information is processed, an appropriate lawful basis, any required additional legal condition and suitable safeguards must apply.

We may collect personal information through:

• Online advertising campaigns.
• Lead-generation forms.
• Marketing landing pages.
• Direct email and business enquiries.
• Appointment requests.
• Introductory communications.
• Business service relationships.

We use GoHighLevel as our customer relationship management and lead-management platform.

When you submit an enquiry, relevant information may be recorded in GoHighLevel so that we can respond, manage the enquiry, carry out basic marketing qualification and facilitate an agreed introduction.

Life Bound Group may contact you about the enquiry you submitted, including to clarify relevant details or assist with an introduction.

Where you have agreed to an introduction, the identified adviser may also contact you about that enquiry, subject to its own legal obligations and the permissions applicable to the communication.

Our general website enquiry facility may open your email application with a prepared message. You decide whether to send it.

Where we collect information through a particular advertising campaign, the relevant privacy information and any necessary consent choices must be presented at the appropriate point of collection.

Where we obtain personal information indirectly and act as controller, we will provide the required privacy information within the applicable legal timeframe, unless a lawful exception applies.

We process personal information only where an appropriate lawful basis applies.

Responding to enquiries

We use your contact details and enquiry information to respond to requests, provide relevant information and manage requested communications.

Lawful basis: Legitimate interests in responding to genuine enquiries and administering our business, where appropriate.

Managing and qualifying enquiries

We may review introductory information to determine whether an enquiry meets general marketing or introductory criteria.

Lawful basis: Legitimate interests in managing enquiries and providing our marketing services, subject to an appropriate balancing assessment.

Facilitating adviser introductions

Where you agree to an introduction, we may share relevant information with one identified financial adviser.

Lawful basis: Your specific, informed consent where we rely on consent for the disclosure.

Contacting you about a requested enquiry

Life Bound Group may contact you to respond to an enquiry, clarify information, arrange an appointment or facilitate an agreed introduction.

Lawful basis: Legitimate interests where appropriate, or consent where required for the relevant processing or communication.

Optional marketing communications

We may send marketing communications where we have the necessary permission or another lawful basis and the communication complies with applicable electronic-marketing rules.

Lawful basis: Consent where required, or legitimate interests where legally available and appropriately assessed.

Business administration

We may process information to manage business relationships, contractual arrangements and relevant service records.

Lawful basis: Contractual necessity where applicable, or legitimate interests in administering business services.

Legal compliance and protecting rights

We may process information to comply with legal obligations, maintain necessary records, investigate complaints or establish, exercise or defend legal claims.

Lawful basis: Legal obligation or legitimate interests, depending on the circumstances.

Where we rely on legitimate interests, we assess the necessity of the processing and its potential impact on individuals.

Providing enquiry information is voluntary. However, without sufficient contact or introductory information, we may be unable to respond or facilitate an introduction.

You are not required to purchase financial advice or any financial product.

Life Bound Group uses separate consent checkboxes on its lead-generation forms.

Where we rely on consent to share personal information with an adviser, the relevant request must identify the intended receiving firm and explain the purpose of the introduction.

Consent must be freely given, specific, informed and expressed through a clear affirmative action.

We do not use pre-ticked consent boxes or treat acceptance of a privacy policy as consent to unrelated marketing.

Where consent is obtained, we maintain appropriate evidence of the consent choice, including when and how it was provided.

Each consenting prospect is introduced to one identified financial adviser.

We do not automatically distribute the same enquiry to multiple unrelated advisers.

Information shared may include:

• Your name.
• Your contact details.
• Your general financial services interests.
• Relevant introductory responses.
• Your contact preferences and information necessary to evidence the agreed introduction.

We limit the information shared to what is appropriate for the stated purpose.

Agreement to an introduction does not automatically authorise unrelated marketing, further adviser introductions or unrestricted onward disclosure.

You may decline an introduction or withdraw consent by contacting info@lifeboundgroup.co.uk.

Withdrawal does not affect processing that was lawful before withdrawal and cannot reverse a disclosure already completed.

Where the adviser acts as a separate controller, you may also contact it directly regarding its use of your information.

Life Bound Group may receive payment from financial services businesses for advertising, marketing, lead-generation and introductory services.

These commercial relationships may influence which advisers participate in our campaigns and receive introductions.

An introduction does not constitute independent financial advice, an impartial whole-of-market comparison, a recommendation of a particular financial product or a guarantee of an adviser's performance.

The receiving adviser is responsible for determining whether it has the necessary regulatory permissions to provide its services and whether it may lawfully advise an individual in the relevant jurisdiction.

Any regulated advice, recommendations, suitability assessments and related advisory responsibilities are the responsibility of the provider undertaking them.

You can check the identity and permissions of a UK financial services firm using the FCA Firm Checker.

FCA authorisation does not mean that the FCA endorses an adviser or guarantees an investment or financial outcome.

Access to the Financial Ombudsman Service or Financial Services Compensation Scheme depends on the relevant firm, service and eligibility requirements.

Nothing in this policy excludes or limits liability that cannot lawfully be excluded, our responsibility for our own activities or your statutory consumer and data protection rights.

We may share personal information where necessary, lawful and consistent with the purposes explained to you.

Recipients may include:

• The one identified financial adviser receiving an agreed introduction.
• GoHighLevel, which supports our enquiry and lead-management activities.
• Email, hosting and other technology providers supporting our operations.
• Professional advisers, including legal and accounting professionals, where reasonably necessary.
• Regulatory authorities, courts, law-enforcement bodies and other public authorities where disclosure is required or otherwise permitted by law.

Where a service provider processes information on our behalf, appropriate data-processing terms and safeguards must apply.

We do not treat consent to one adviser introduction as permission for unrestricted sharing with other advisers or unrelated businesses.

We do not use personal information for unrelated third-party marketing without an appropriate lawful basis and any legally required permission.

Life Bound Group uses GoHighLevel, a platform operated by HighLevel, Inc., a United States-based business.

Personal information processed through GoHighLevel may be transferred to, stored in or accessed from the United States or other countries in which relevant providers or subprocessors operate.

Where a transfer is subject to restrictions under UK data protection law, an appropriate transfer mechanism must apply.

Depending on the circumstances, this may include:

• Applicable UK adequacy regulations.
• A valid arrangement under the UK Extension to the EU–US Data Privacy Framework, where the relevant recipient and transfer are covered.
• The UK International Data Transfer Agreement.
• The UK Addendum to EU Standard Contractual Clauses.
• Another legally recognised transfer mechanism or exception.

Where required, appropriate transfer risk assessments and supplementary safeguards must also be implemented.

Where EU GDPR applies, relevant EU international transfer requirements must also be satisfied.

Consent to an adviser introduction does not, by itself, provide a general legal safeguard for routine international transfers.

You may contact info@lifeboundgroup.co.uk for information about the applicable transfer arrangements and how to obtain details of relevant safeguards.

Life Bound Group retains personal information only for as long as necessary for the purpose for which it was collected, subject to applicable legal obligations and other justified retention requirements.

Retention decisions take account of the nature of the information, the purpose of processing, whether an enquiry remains active, whether an introduction has been completed and whether continued retention is legally necessary.

Different retention criteria apply to:

Active enquiries: Information is retained while reasonably necessary to respond to and manage an active enquiry.

Inactive and unconverted leads: Information is reviewed when it is no longer needed for an active enquiry and must be deleted or anonymised when no lawful retention purpose remains.

Completed introductions: Relevant information may be retained where necessary to administer the introduction, maintain proportionate evidence of the transaction or address a legitimate complaint or legal claim.

Consent and preference records: Information may be retained where necessary to demonstrate compliance, honour withdrawals and objections, or address relevant disputes.

Business and accounting records: Relevant information is retained for applicable statutory or justified business record-keeping periods.

Marketing suppression records: Minimal information may be retained where necessary to ensure that objections to direct marketing continue to be respected.

We do not retain personal information indefinitely merely because it may be useful in the future.

Where information is no longer required, it must be securely deleted or anonymised, subject to applicable legal requirements and justified exceptions.

You may contact us for further information about the retention criteria applicable to your personal information.

We recognise our obligation to implement appropriate technical and organisational measures to protect personal information against unauthorised access, accidental loss, alteration, disclosure and unlawful processing.

Security arrangements must be proportionate to the nature of the information, the purposes of processing and the associated risks.

Appropriate measures may include:

• Access controls and account permissions.
• Secure handling and transmission procedures.
• Staff responsibilities and confidentiality requirements.
• Service-provider oversight.
• Appropriate incident-response procedures.
• Regular review of relevant security risks.

No electronic transmission or storage method can be guaranteed to be completely secure.

Where a personal data breach occurs, we assess and document the incident and comply with applicable regulatory reporting and notification requirements.

Where a breach is reportable to the ICO, notification must be made without undue delay and, where feasible, within 72 hours of becoming aware of it.

Where a breach is likely to result in a high risk to individuals, affected individuals must also be notified without undue delay unless a lawful exception applies.

Life Bound Group does not currently use advertising tracking pixels on its marketing landing pages.

Essential cookies or similar technologies may be used where necessary for website functionality, security or the operation of enquiry forms.

The use of cookies and similar technologies is subject to applicable privacy and electronic communications requirements.

Where consent is legally required for non-essential technologies, those technologies must not be used before valid consent has been obtained.

Where applicable, users must receive clear information about the relevant technologies and have an appropriate opportunity to accept, reject or change their preferences.

If we introduce advertising pixels, analytics technologies or other non-essential tracking in the future, we will review and update the relevant privacy information and implement any necessary consent arrangements before using those technologies.

Life Bound Group distinguishes between:

• Responding to a requested enquiry.
• Contacting an individual about an agreed introduction.
• Sending optional direct marketing communications.

Submitting an enquiry does not automatically constitute permission to receive unrelated marketing.

Where consent is required for marketing emails, text messages, automated calls or other relevant communications, we will obtain the necessary permission.

Where another lawful route is available, we will comply with the applicable conditions.

Both Life Bound Group and the receiving adviser are responsible for complying with the rules applicable to their own communications.

Where unsolicited live marketing calls are made, relevant consent, screening and objection requirements must be satisfied, including applicable Telephone Preference Service requirements.

Additional restrictions may apply to particular financial services marketing activities, including pension-related marketing.

You have an absolute right to object to the processing of your personal information for direct marketing purposes, including related profiling.

You may withdraw marketing consent or object to direct marketing at any time by contacting info@lifeboundgroup.co.uk.

Where you object, we will stop processing your personal information for those purposes.

We may retain minimal suppression information where necessary to respect your preferences and avoid further unwanted marketing.

Life Bound Group may use information supplied through enquiry forms to determine whether a prospect meets general marketing or introductory criteria.

This may involve reviewing location, general service interests, stated preferences and whether the individual wishes to speak with an adviser.

Marketing qualification is not an assessment of financial suitability, affordability, investment risk or eligibility for a particular financial product.

Where automated processing or profiling takes place, we must comply with applicable transparency and data protection requirements.

Where a decision is made solely through automated processing and produces legal or similarly significant effects, the applicable legal conditions, safeguards and individual rights must be respected.

Under applicable data protection law, you may have the following rights, depending on the circumstances.

Right of access: Request confirmation of whether we process your personal information and obtain access to it.

Right to rectification: Request correction of inaccurate personal information or completion of incomplete information.

Right to erasure: Request deletion of personal information where the relevant legal conditions apply.

Right to restriction: Request that processing be limited in certain circumstances.

Right to data portability: Request eligible personal information in a structured, commonly used and machine-readable format where the relevant conditions apply.

Right to object: Object to certain processing, including processing based on legitimate interests.

Right to object to direct marketing: Require us to stop processing your information for direct marketing purposes, including related profiling.

Right to withdraw consent: Withdraw consent at any time where processing relies on it.

Rights relating to automated decisions: Exercise applicable rights and safeguards concerning qualifying solely automated decisions.

To exercise your rights, contact:

Email: info@lifeboundgroup.co.uk

Post: Life Bound Group Ltd, 66 Paul Street, London, EC2A 4NA, United Kingdom.

You do not need to use a particular form or legal wording.

We may request proportionate information to verify your identity.

We will respond without undue delay and within the applicable statutory timeframe, generally one month, subject to any lawful extension or other applicable procedural rule.

Requests are normally free, although limited exceptions may apply.

Some rights are subject to legal conditions and exemptions.

If you have concerns about how Life Bound Group handles your personal information, please contact:

info@lifeboundgroup.co.uk We will review your concern and respond appropriately.

You also have the right to complain directly to the Information Commissioner's Office (ICO), the UK's data protection regulator.

ICO website: https://ico.org.uk/make-a-complaint/

You do not need to contact us before raising a complaint with the ICO.

Where EU GDPR applies, you may also have the right to complain to an appropriate EU supervisory authority.

Complaints concerning regulated financial advice or services provided by an adviser should be directed to the relevant firm through its complaints procedure.

This does not restrict your right to raise complaints or legal claims concerning Life Bound Group's own activities.

Our website and communications may contain links to third-party websites, including those operated by financial services providers.

Those organisations may have their own privacy notices, terms and data protection responsibilities.

We encourage you to review their privacy information before providing personal information directly to them.

Life Bound Group remains responsible for its own processing activities and applicable legal obligations.

We may update this Privacy Policy to reflect changes in our services, data-processing activities, technology providers or applicable legal requirements.

Where required, we will inform individuals about material changes and obtain additional consent before undertaking new processing activities that require it.

The latest version will be made available through our website together with its last-updated date.

Life Bound Group Ltd, 66 Paul Street, London, EC2A 4NA, United Kingdom

Email: info@lifeboundgroup.co.uk

Data protection: Applicable ICO data protection fee up to date.

Regulatory status: Life Bound Group is not FCA-authorised and does not provide regulated financial advice.

This Privacy Policy explains our handling of personal information and our commercial introductory role. It does not constitute financial advice, FCA authorisation, approval of a financial promotion or permission to carry on regulated activities.