This Privacy Notice explains how Seb Gladwish Money Limited collects, uses, stores and protects personal information when you visit the SGM website, contact SGM, subscribe to updates, purchase or download resources, or use SGM’s non-regulated divorce administration, education and consulting support services.
SGM is committed to handling personal information fairly, lawfully and transparently in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and, where relevant, the Privacy and Electronic Communications Regulations 2003 (PECR).
1. Who we are
· Business name: Seb Gladwish Money Limited (company number: 17397257
· Email: sebastian@sebgladwishmoney.co.uk
· Registered office: 71-75, Shelton Street, London, WC2H 9JQ
For the purposes of UK data protection law, SGM Limited is the data controller for the personal information described in this Privacy Notice. This means SGM decides why and how that information is used.
2. Scope of this Privacy Notice
This Privacy Notice applies to:
· visitors to the SGM website;
· people who submit an enquiry or contact form, email SGM, or otherwise ask about SGM services;
· clients who use SGM services;
· people who subscribe to newsletters or updates;
· people who purchase or download SGM resources, where applicable;
· people who attend calls, meetings, webinars, workshops or events delivered by SGM;
· people who interact with SGM through social media or other online channels; and
· professional contacts, including solicitors, mediators, divorce coaches, accountants, financial advisers and other introducers.
3. What personal information we collect
Depending on how you interact with SGM, we may collect and use the following types of information:
· Identity and contact details: name, email address, telephone number, postal address and preferred contact method.
· Client and enquiry information: information you provide when enquiring about or using SGM services, including notes from meetings, calls, emails and consulting sessions.
· Financial information: information you choose to share about income, expenditure, assets, liabilities, budgets, property, pensions, savings, debts or other financial circumstances.
· Divorce and family-related information: information relevant to divorce, separation, financial disclosure, dependents, children, living arrangements, solicitors, mediators or other professionals involved.
· Documents and records: documents you choose to provide, such as budgets, statements, schedules, checklists, disclosure documents or other supporting information.
· Payment and billing information: invoices, payment records and transaction references. SGM does not intend to store full payment-card details directly.
· Website and technical information: IP address, device type, browser type, pages visited, approximate location, referral source, website activity and cookie or similar technology information, where applicable.
· Form and newsletter information: information submitted through the SGM website, including contact forms, enquiry forms and newsletter sign-up forms.
· Marketing preferences: whether you have opted in to receive updates, newsletters or other marketing communications.
4. Sensitive information and special category data
SGM may receive special-category personal information, particularly information concerning health, disability, sex life or sexual orientation. SGM will only collect or retain this information where it is genuinely relevant and necessary. Where SGM relies on explicit consent under Article 9 UK GDPR, that consent will be requested separately and recorded. You may withdraw that consent, although this may affect SGM’s ability to continue providing parts of the service.
Please avoid providing unnecessary sensitive information about another person. Where documents contain information about a spouse, former partner, child or other third party, provide only what is relevant and redact unnecessary identifiers where appropriate.
5. Information about other people
In the context of divorce or separation, you may provide information about other people, such as a spouse, former partner, children, dependents, family members, solicitors, mediators or other professional advisers.
Please only provide information about other people where it is relevant and necessary for the service. Where possible, avoid providing unnecessary identifiers such as full dates of birth, addresses, National Insurance numbers, policy numbers or account numbers. If you provide information about another person, SGM will treat it confidentially, use it only for relevant purposes and will not contact that person or share their information unless required by law, necessary to provide the service, or agreed with you.
6. Information about children
SGM may receive limited personal information about children where it is relevant to household finances, care arrangements or the practical organisation of divorce or separation. SGM will seek to collect and retain only the information reasonably necessary for the relevant service.
Please avoid providing unnecessary identifying or sensitive information about children. SGM will not use children’s personal information for marketing or for purposes unrelated to the service being provided.
7. How we collect information
We may collect personal information directly from you when you:
· visit or use the SGM website;
· complete an enquiry or newsletter form;
· email SGM through Google Workspace / Gmail, call, message or meet with SGM;
· provide documents, spreadsheets or other information for review or discussion;
· book or attend a session, meeting, webinar or workshop;
· purchase or download an SGM resource, where applicable;
· make a payment; or
· interact with SGM on social media.
We may also receive limited information from professional introducers, such as solicitors, mediators or divorce coaches, where you have asked them to introduce you to SGM or where they have a lawful basis to do so.
Information submitted through the SGM website may be processed through Squarespace and delivered to SGM’s business email account. Depending on the website configuration, a copy of a form submission may also be retained within Squarespace or another connected service.
8. How we use your information
We use personal information for the following purposes:
· to operate, maintain and secure the SGM website;
· to respond to enquiries and provide information about SGM services;
· to assess whether an enquiry falls within the scope of SGM’s services;
· to provide practical educational, organisational and consulting support in relation to divorce and separation;
· to prepare for and deliver meetings, calls, workshops or consulting sessions;
· to help clients organise information, documents, checklists and questions for other professionals;
· to create and maintain client records;
· to issue invoices, process payments and manage accounts;
· to provide requested downloads or resources;
· to understand website use and improve website content and services, where analytics are enabled and lawfully used;
· to comply with legal, tax and accounting obligations;
· to manage complaints, disputes or queries;
· to maintain security and prevent misuse of systems; and
· to send marketing communications where you have opted in or where the law otherwise permits.
9. Lawful bases for using your information
SGM relies on one or more of the following lawful bases under UK GDPR:
Purpose
Personal information used
Lawful basis
Responding to enquiries and providing service information
Contact details and enquiry information
Legitimate interests and/or steps before entering a contract
Providing SGM services
Client information, financial information, session notes and documents you provide
Contract
Processing sensitive or special category data where relevant
Health, vulnerability, disability or other sensitive information you choose to share
Explicit consent and/or another applicable Article 9 condition
Invoices, payments, accounting and tax records
Billing details, payment records and correspondence
Legal obligation and legitimate interests
Managing complaints, disputes or legal issues
Relevant client records and correspondence
Legitimate interests and legal obligation
Marketing updates or newsletters
Name, email address and marketing preferences
Consent, or the soft opt-in where all applicable legal requirements are met. Every marketing communication will provide a straightforward way to opt out.
Website operation and security
Technical and usage information and strictly necessary cookie data
Legitimate interests and/or necessity for providing the website service
Non-essential website analytics or similar technologies
Technical, cookie and website usage information
Consent where required
Providing information is generally voluntary. However, SGM may be unable to respond fully to an enquiry or provide an agreed service if information reasonably required for that purpose is not supplied.
10. Who we share your information with
SGM will not sell your personal information or share it with third parties for their own marketing purposes.
SGM operates separately from HFMC Wealth. SGM and HFMC Wealth are separate data controllers, with separate systems and client records. Personal information provided to SGM will not automatically be available to HFMC Wealth or stored on HFMC systems. Information will only be shared with HFMC Wealth where there is an appropriate lawful basis, the purpose has been clearly explained to you and, where required, you have given your consent.
SGM uses third-party technology and professional service providers to run the business. These may include:
· Squarespace, which provides the SGM website, domain-related services and website forms and may process website visitor and form data;
· Google Workspace, including Gmail and Google Drive, for business email, calendar and cloud-based document storage;
· payment processors and banking providers used to receive or administer payments;
· accounting, bookkeeping, electronic-signature, document-storage, IT support and other business software providers;
· professional advisers or third parties where you have asked SGM to make an introduction or share information, such as a solicitor, mediator, divorce coach, accountant, tax adviser or FCA-authorised financial adviser;
· HMRC, regulators, law-enforcement bodies, courts or other authorities where required by law; and
· insurers or legal advisers if needed to manage a complaint, claim or dispute.
Where a service provider acts as a processor on SGM’s behalf, SGM will take proportionate steps to use appropriate contractual and data-protection arrangements. Providers may only process personal information for authorised purposes and in accordance with the relevant agreement or instructions.
11. International transfers
Some technology providers used by SGM, including Squarespace and Google, may process or store personal information outside the UK. Where personal information is transferred internationally, SGM will rely on an appropriate lawful transfer mechanism, such as an adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another lawful safeguard where applicable. You may contact SGM for further information about the safeguards relevant to your information.
12. How long we keep your information
SGM will only keep personal information for as long as necessary for the purposes described in this Privacy Notice. As a general guide:
· client records: up to 6 years after the end of the client relationship;
· invoices, payment and tax records: usually 6 years, in line with accounting and tax record-keeping requirements;
· enquiry records where no client relationship begins: up to 12 months, unless there is a reason to keep them longer;
· marketing records: until you unsubscribe, withdraw consent or the mailing list is reviewed;
· website form submissions: for as long as reasonably necessary to deal with the enquiry or purpose for which the form was submitted; and
· website analytics and cookie data: in line with the relevant cookie settings and provider retention periods.
When information is no longer required, SGM will securely delete, destroy or anonymise it.
13. How we protect your information
SGM takes proportionate steps to protect personal information, including:
· using password protection, multi-factor authentication where available, and appropriate access controls;
· limiting access to information to those who need it for legitimate purposes;
· using reputable website, email and cloud-storage providers;
· using secure document storage and payment tools where practical;
· keeping software and devices reasonably up to date; and
· taking reasonable care when sharing documents or information with third parties at your request.
No method of electronic transmission or storage is completely secure, but SGM will take proportionate steps to reduce risk and protect client confidentiality.
14. Website, Squarespace, cookies and analytics
The SGM website is hosted using Squarespace. Squarespace may process technical information about website visitors and uses cookies or similar technologies that are necessary to operate and secure the website. Depending on SGM’s website settings and the features used, Squarespace may also provide analytics or performance information.
Where cookies or similar technologies are not strictly necessary, SGM will use the website’s consent tools so that they are not used until the visitor has made the relevant choice, where consent is required by law. Visitors will be given clear information about cookie use and a way to manage or withdraw their choices.
If SGM enables third-party embeds, analytics, payment tools, social-media integrations or other website features, those providers may also process limited technical information or place cookies. The SGM Cookie Notice and website cookie settings should be reviewed whenever new website features are added.
A separate Cookie Notice may provide more detailed information about the specific cookies and similar technologies used on the live website, their purpose, duration and how visitors can manage their preferences.
15. Website forms and email
When you submit a form through the SGM website, the information you provide will be used for the purpose stated on or reasonably apparent from the form, such as responding to an enquiry or adding you to a mailing list where you have chosen to subscribe.
SGM uses Google Workspace for email services. Emails and attachments sent to SGM may therefore be processed and stored within Google Workspace. Please avoid sending unnecessary highly sensitive information by ordinary email. Where appropriate, SGM may provide a more suitable method for sharing documents.
16. Marketing communications
SGM will only send marketing communications where permitted by law. If you subscribe through the website, your name, email address and marketing preferences may be processed through the website or email-marketing service used by SGM. You can opt out at any time by using the unsubscribe link in a marketing email, where available, or by contacting SGM directly.
Opting out of marketing will not stop SGM from sending service-related communications, such as appointment reminders, invoices, client documents or information needed to provide an agreed service.
17. Non-regulated service reminder
SGM provides divorce administration, education and consulting support. SGM does not provide FCA-regulated financial advice, legal advice, tax advice, product recommendations, pension transfer advice, investment advice or personal recommendations on regulated financial arrangements.
Where you need regulated financial advice, legal advice, tax advice or another professional service, SGM may signpost you to an appropriate professional. Information may only be shared with them where there is an appropriate lawful basis, such as your consent or another legal basis.
18. Your rights
Under UK data protection law, you have rights over your personal information. Depending on the circumstances, these may include the right to:
· access the personal information SGM holds about you;
· request correction of inaccurate or incomplete information;
· request deletion of information in certain circumstances;
· request restriction of processing in certain circumstances;
· object to processing in certain circumstances;
· request transfer of information to another organisation in certain circumstances;
· withdraw consent where processing is based on consent;
· object to direct marketing at any time; and
· complain to the Information Commissioner’s Office (ICO).
These rights are not absolute and may depend on the circumstances. To exercise your rights, please contact SGM using the details in section 1.
19. Complaints
If you have any concerns about how SGM handles your personal information, please contact sebastian@sebgladwishmoney.co.uk
20. Updates to this Privacy Notice
SGM may update this Privacy Notice from time to time, including where website features, technology providers or business arrangements change. The latest version will be available on the SGM website or provided on request. If significant changes are made that affect how personal information is used, SGM will take reasonable steps to bring those changes to your attention.
