Regulatory Statement

The information published on the Firco Group website is provided as a convenience to visitors and should be used for information purposes only and is subject to change without notice. None of the information contained in this website constitutes financial or other professional advice in any way. If you require additional information, you should contact Firco Group.

While Firco Group uses reasonable efforts to ensure that the information contained on its website is current and accurate at the date of publication, no warranties are made, either expressed or implied, as to reliability, accuracy or completeness of the information. Firco Group accepts no liability for any loss arising directly or indirectly from the use of or action taken in reliance on such information. These documents should not be copied, reproduced or redistributed, in whole or in part.

No warranty is given as to the freedom of this website from errors, defects, viruses, malicious programs or macros.

Pinsa Wealth Ltd Registered in England, No: 10334603
Registered Office: 62 Dunbabin Road, Childwall, Liverpool L16 7QH

Firco is a trading style of Pinsa Wealth Ltd which is authorised and regulated by the Financial Conduct Authority (FCA). The FCA regulates financial services in the UK and you can check our authorisation and permitted activities on the Financial Services Register or by contacting the FCA on 0800 111 6768. Our Financial Services Register number is 760774.

Client Classification Levels For Your Protection
The FCA has rules which affect the rights you have as a customer. In our dealings with you we will be representing you as the customer, rather than acting on behalf of an insurer.

We classify all our individual customers as ‘retail’ customers. The range of financial products we recommend are tailored to meet the needs of retail customers. You will have rights under the Financial Ombudsman Service (FOS) and the Financial Services Compensation Scheme (FSCS). These rights will apply to the provision of the advice we provide.

There are other classifications of customer that don’t have these rights. These are “professional” customers and “eligible counterparties”.

You have the right to be classified as a professional client and revoke this status on request. Should you feel you have the skills knowledge and experience to be a professional client and don’t wish to have the same protection afforded to retail clients, please let me know and we will complete the forms necessary to reclassify you.

If you have any questions regarding your classification (e.g. if you are a large company), please write to Firco Compliance Department, 62 Dunbabin Road, Childwall, Liverpool L16 7QH or to the Financial Ombudsman Service and FSCS.

Our blog, case studies and market analyses reflect the personal views of the authors and do not necessarily represent the views or opinions of Firco. All comments are made in good faith and we do not accept liability for them. Older articles are available on this website; please bear in mind this means some of the information they contain may have become outdated.

The information in the Firco blogs is not intended as an offer or solicitation to buy or sell securities or any other investment or banking product, nor does it constitute a recommendation to buy or sell such products. Nothing in this material constitutes investment, legal, credit, accounting or tax advice or a representation on that any investment or strategy is suitable or appropriate to your individual circumstances.

The value of investments, and the income from them, can go down as well as up, and you may not recover the amount of your original investment. Past performance should not be taken as a guide to future performance. Where an investment involves exposure to a foreign currency, changes in rates of exchange may cause the value of the investment, and the income from it, to go up or down. For some investments, there is no recognised market. Therefore it may be difficult to deal in them or obtain reliable information about their value or the extent of the risks to which they are exposed. Investments in emerging markets are subject to certain special risks, e.g. the risk of political instability, unpredictable financial market trends and economic growth patterns, a financial market that is still in the development stage and a weak economy.

The information in these blogs is believed to be correct but cannot be guaranteed. Any opinion or forecast constitutes our judgment as at the date of issue and is subject to change without notice.

The analysis contained in the Firco blogs has been procured, and may have been acted upon, by Firco and connected companies for their own purposes, and the results are being made available to you on this understanding. To the extent permitted by law and without being inconsistent with any applicable regulation, neither Firco nor any connected company accepts responsibility for any direct or indirect or consequential loss suffered by you or any other person as a result of your acting, or deciding not to act, in reliance upon such information, opinions and analysis.

Neither any blog post nor any copy thereof may be sent to or taken into jurisdictions where the distribution may be restricted by local law or regulation. The reproduction, publication and/or distribution of any of Firco blog posts in whole or part without prior permission of Firco is prohibited.

Posting on Firco Blogs
By submitting comments or any other material for publication on the Firco blogs, you grant Firco a worldwide, royalty-free, non-exclusive and perpetual licence to use in any way whatsoever any comments or material submitted to us in any format. This licence includes, but is not limited to, the right to develop, reproduce, modify, adapt, implement, publish, distribute and display the comments or material in any medium.

In addition, by posting a comment or any other material on the Firco blogs, you warrant that this material belongs to you and that your submission of it does not infringe the intellectual property rights of any third party.

We will attempt to check every comment submitted before it is published on any of the Firco blogs to ensure it complies with our standards but we cannot guarantee the same. We reserve the right to refuse, in our absolute discretion, to allow or to delay posting of all or any part of any comments or other material and to edit or remove any comments or other material posted to the blog. We reserve the right to preserve any content you may post to the extent required by law or the rules of any regulatory authority to protect the rights, property or personal safety of the blog, its users, the public, and Firco.

Nonetheless, we assume no responsibility for monitoring the blog for inappropriate content or conduct, no obligation to modify or remove any inappropriate content and no responsibility for the conduct of the user of submitting any such content.

If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third-party data processor. The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.

Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter. While your email address remains within the MailChimp database, you will receive periodic emails from us.

These House Rules apply to social media accounts operated by Firco (‘Firco’, ‘us’, ‘we’, ‘our’) on social media platforms, including but not limited to, Facebook, LinkedIn, Twitter and YouTube.

Any references in these House Rules to ‘you’, ‘your’ or ‘yours’ are references to the person(s) using our social media accounts.

We have designed these House Rules so you can interact with us in a safe and appropriate way. If you do not accept these House Rules, please do not use our social media accounts.

The basic rule for using our social media accounts is:

Only post information you are happy for everyone to see

Do’s and don’ts

Do’s

• Do keep your comments or messages succinct.
• Do keep comments or messages on-topic.
• Do only comment or message us with your own opinions.

Don’ts

• Don’t comment or message personal or confidential information.
• Don’t use offensive, indecent or obscene language that could be discriminatory or promotes discrimination of any kind, or that may be considered as bullying or harassment;
• Don’t use our social media accounts to incite, condone or encourage conduct which could result in a criminal offence, civil liability or otherwise breach any laws or regulations including any laws regarding competition.
• Don’t comment or message anything that could be considered defamatory or embarrassing, or damaging to an individual, company or entity’s reputation.
• Don’t post links or direct others to material containing viruses, corrupted files or anything that may cause damage to or interfere with computer hardware or software or to material which is offensive, indecent, obscene or may otherwise breach the terms of use of the relevant social media account.
• Don’t use our social media accounts in any way which is anti-competitive or could be expected to give rise to anti-competitive behaviour.

If you don’t comply with these House Rules we may delete your comments or block you from our social media accounts.

Management of our social media accounts
Our social media accounts may be managed by Firco employees and / or third parties appointed by the Firco. We cannot moderate what others post about Firco before it is posted, but we may (if we are able) remove posts which don’t comply with our House Rules.

Views and opinions
Social media platforms are independent third party websites and are not associated with Firco; we can’t control what they do.

With the exception of our own comments and messages, the views and opinions expressed on our social media accounts are the views and opinions of the person posting the information and are not our views or those of Firco. While we try to ensure that the information on our site is current, we cannot guarantee that the information provided on our social media accounts will be complete, accurate or up-to-date.

Complaints
If you would like to make a formal complaint about the financial or other services we provide, please follow our complaints procedure. If you do make a complaint through our social media accounts, we will try to collect details of the complaint, using secure communication. We will attempt to resolve your complaint through our standard customer complaint procedure.

Using your comments, ideas and images
You confirm any material (like suggestions, ideas, videos or photos) you post or message to our social media accounts belongs to you and does not infringe anyone else’s intellectual property rights. Unless prohibited by the social media platform’s own terms of use, you also grant Firco a non-exclusive royalty-free, perpetual, worldwide licence to use develop, reproduce, modify, adapt, publish, distribute, and display the material in any medium.

Our materials and intellectual property
Our names, images, trade marks and other materials contained on our social media accounts are protected by intellectual property rights. You must not use these materials for any reason without our express consent.

External websites
Where there are links to third party websites or resources, whether posted by us or a third party, you access these at your sole discretion and at your own risk. We are not responsible or liable for any damage caused by third party websites or resources.

Please note that external websites are governed by their own terms of use and privacy policies and you should read these carefully.

Advice
Our comments or messages are not intended to provide any financial, investment or professional advice and shall not be deemed to constitute the offer or provision of financial, investment or other professional advice in any way. You should obtain advice from a qualified financial advisor before making any investment decision.

Changes
We reserve the right to amend these House Rules at any time without prior notice. We will notify you on our social media account when there has been a change to these House Rules. You should make sure you are complying with the current House Rules.

We reserve the right to close our social media accounts at any time, without prior written notice.

Notices
Please do not issue any formal notices to us through our social media accounts. These should be sent to our office address which is indicated below within the ‘Contact Us’ page.

The law governing this agreement both before and after completion is the law of England and Wales.

We normally require our clients to give us instructions in writing, to avoid possible disputes, but we shall be entitled, at our sole discretion, to act upon your oral instructions. We can refuse your instructions at our discretion.

We may vary the terms of this agreement by writing to you at your last know address. Proof of delivery to this address will constitute proof of notice being served.

No Liability
The information on this website is provided “as is” and has been compiled in good faith to provide information about Firco and its products and services. It is believed to be correct, but we cannot guarantee the accuracy, timeliness, or completeness of any such information. Firco shall not be liable for any loss or damage whatsoever and howsoever arising as a result of your use of or reliance on the information contained on this website.

Before acting on any information obtained from this website you should check it by calling Firco.

Nothing contained on this website constitutes investment, legal, tax or other advice and is not to be relied on in making an investment or other decision. You should obtain relevant and specific professional advice before making any investment decision.

Firco reserve the right to modify, suspend, or discontinue this website or any part of it, with or without notice, at any time, and shall not be liable to you or to any third party for any such modification, suspension or discontinuance of this website.

Firco shall not be liable for any losses or damages of any kind arising out of your use or inability to use this website, or in connection with any error, omission, or defect contained on this website. Furthermore, Firco accepts no liability in respect of losses or damages arising out of changes made to the content of this website by unauthorised third parties.

Access to and use of this website is at your sole risk and Firco does not warrant that the use of this website or any material downloaded from it will not cause damage to any property, including but not limited to loss of data or computer virus infection.

There is no exclusion of duties or liabilities, or any conduct of business rules which Firco are bound to comply with. There is no attempt to exclude liability for death, personal injury, or fraudulent misrepresentation.

No Offer
Nothing on this website should be construed as a solicitation or offer, or recommendation, to buy or sell securities or any other investment or banking product, or to provide any investment advice or service.

Investment Advice
We provide independent investment advice. We will consider a range of regulated products from the available market that can meet the investment objectives of a retail client but we will only provide a recommendation to you when we know the product is suitable for your personal circumstances.

We will inform you if any investment we recommend restricts future access to your capital.

Mortgages
We are independent mortgage advisers and we will advise & recommend a mortgage product that is suitable for you following an assessment of your personal needs and circumstances. This will include a detailed assessment of affordability.

We will consider all products and lenders that we have access to, representative of the whole of the market. This means we will not consider those lenders that are only available by you going direct to them.

Where you are increasing your borrowing, we will consider the merits of both a new first charge mortgage and securing this by an additional mortgage on a second charge basis. You may also have the option of a further advance from your existing lender or borrowing through an unsecured loan but whilst these may be more appropriate for you, we will not consider these when making our recommendation to you.

Where we have quoted mortgage rates, the actual rate available will depend on your circumstances. Ask for a personalised illustration.

As a mortgage is secured against your home, it could be repossessed if you do not keep up the mortgage repayments.

Non-Investment Protection
For Non-investment protection contracts we are an intermediary and will act on your behalf when providing advice and making our personal recommendation(s) to you. We will do this based on a fair and personal analysis of insurers for term assurance, income protection, critical illness from a range of insurers. We will provide you with advice and arrange the contract on your behalf after an assessment of your personal needs and circumstances.

General Insurance
For general insurance contracts we are an intermediary and will act on your behalf when recommending an insurer based on your demands and needs from a fair analysis of the market. The insurers we consider will be listed to you when we carry out our research. It will be your responsibility to ensure the policy meets your demands and needs for building and/or contents, private medical insurance, accident sickness and unemployment.

Full details of the products we recommend will be confirmed in the product literature you will receive before it is arranged.

This website contains hypertext links to other websites which are hosted and maintained by third parties and which are not, or may not be, regulated. When you activate any of these links you leave the Firco website and we have no control over the content or security of any such site. You use such links entirely at your own risk and Firco accept no responsibility or liability for the content, use, or availability of such websites or for any loss or damage, however arising, as a result of their use.

Links from this website exist for information only and Firco Group accepts no responsibility or liability for the information contained on any such site. The existence of a link to another website does not imply or express endorsement of its provider, product or services by Firco Group. Links to this website are not permitted without the prior written consent of Firco Group. Please note that clicking on links to external websites will cause you to leave the Firco Group website.

In all cases we will communicate the risks to you both verbally and in writing. The performance of an investment is not guaranteed and you are not certain to make a profit.

Past performance should not be taken as a guide to future performance. The underlying value of investments, and the income from them, can go down as well as up, and you may not recover the full amount of your original investment.

Whenever we carry out any investment business services for you, we shall point out to you our understanding of the advantages and disadvantages involved and the degree of investment risk to which you will be subject. You, the client, will ultimately take full responsibility for the final selection and choice of any investments made.

In the case of some investments, you should be aware that there is no recognised market for them and that it may therefore be difficult for you to deal in them or to obtain reliable information about their value or the extent of the risks to which they are exposed.

Certain investments carry a higher degree of risk than others and are, therefore, unsuitable for some investors. Before contemplating any transaction, you should consider whether you require financial advice, which we would be pleased to provide upon request.

Whilst a portfolio of investments specially selected to meet your requirements can be expected to perform in a broadly similar way to the market as a whole, some divergence will be experienced, especially over the short to medium term.

Before contemplating any transaction in an investment programme, you should have read the prospectus relating to the relevant investment programme and consulted your Firco wealth manager.

Execution Only
If you choose to use our execution only dealing service we will not provide investment recommendations to you. Accordingly, when giving orders or instructions to us, you must rely upon your own judgement and in every case the transaction will be your responsibility.

Where you select your own investments or protection policies and are not receiving any recommendation from us as to their suitability or merit, then you take responsibility for those investments’ or policies’ suitability to your circumstances and requirements.

If we agree to arrange such self-selected investments or policies for you, we may do so subject to an ‘appropriate-ness test’ to confirm your understanding of the nature of the investments or protection policies and the risks involved.

Currency Risks
Where an investment involves exposure to a foreign currency, changes in rates of exchange may cause the value of the investment, and the income from it, to go up or down.

If applicable, you must also be aware that offshore investments may be subject to an additional risk in terms of exchange rate fluctuations between the currency of the original funds and the currency of a chosen investment.

You also acknowledge that as the client, you should ensure that you understand any exchange control, tax, insurance legislation that may exist in your country and how it affects any investments.

It is in the interests of our clients and Firco that we obtain the best possible result when placing orders with other firms (e.g. third party brokers) for the execution of client orders or when transmitting orders on behalf of clients for particular investments, e.g. collective funds, structured products or shares.

Where we place or transmit orders for such investments on behalf of our clients, we may utilise the services of a third party broker and base our decision to place or transmit an order on the price and cost of execution of the order. For orders in collective investment schemes (e.g. unit trust), however, the price of units or shares in the scheme is normally set by the scheme operator or manager and as such we have little influence over the price available.

As part of our service we may decide to refer you to a Discretionary Fund Manager (DFM) to manage some or all of your investments. We will only do this if we think it is a suitable solution for you. We will explain to you in writing why we have recommended the services of a DFM and how the selected DFM will manage your money.

The Discretionary Fund Manager Service offers you direct access to investment expertise through a diversified investment portfolio. The DFM will build the initial asset allocation in line with your investment objectives and risk profile. A dedicated portfolio manager will work alongside your Firco private wealth manager to make tactical adjustments throughout the life of your investment, adapting your portfolio as financial markets change. Working closely with you and your Firco private wealth manager, the DFM Investments Solutions will ensure that your portfolio strategy complements your overarching wealth circumstances and, as always with Firco, will be delivered with a high touch, proactive and personal service.

Firco referral to a DFM Service seeks to balance income-generating assets with those offering compelling medium-term growth potential. Controlled through effective portfolio construction and diversification, risk management is central to our approach as we draw on extensive tools and analytics from the DFM to ensure alignment with your individual risk profile.

Firco DFM Service provides access to a range of active and passive investments, including collective investment schemes, index funds and exchange traded funds (ETFs). Structured products may also be used to take advantage of tactical views and strategies. The portfolio focuses on a range of global government bonds, corporate and high yield debt, with a significant proportion allocated to equities in the UK, and in the wider developed and emerging markets. Assets will be owned within your portfolio, and held by the DFM – or an appointed custodian – on your behalf.

If, once having assessed your needs and objectives, we consider that a DFM service is an appropriate solution for you we will:

• Undertake appropriate due diligence and recommend a DFM service/provider that we believe best meets your needs and objectives.
• Attend initial meetings with you and the DFM
• Ensure that your relationship with the DFM is established correctly
• Review the DFM’s performance on a six monthly/annual basis
• Attend annual review meetings to ensure the DFM service continues to meet your agreed needs, objectives and mandate

There will be no additional charge from Firco for providing this service. Any work involved is included as part of our initial and ongoing fee charges for our services levels. However, the DFM may charge their own fees for providing their services, this will be sent to you prior to you making your decision.

At Firco, we place great importance on providing the highest standards of service to our clients.

However, we recognise that occasionally we do make mistakes. In these instances, we encourage our clients to advise us of their complaints so that we have the opportunity to put matters right.

We aim to get your complaint resolved as quickly as possible by staff with the right experience, knowledge and authority.

We want to:

• make it easy for you to raise your complaint;
• listen to your complaint;
• consider your suggestions for how we can put matters right;
• make sure you are satisfied with how your complaint was handled and resolved;
• be polite, efficient and fair in all of our dealings with you.

This page explains what to do if you have a complaint about our services. It also outlines the timescales you should expect for resolving complaints and who to contact if you are not satisfied with our response.

How and where to complain
If you are not satisfied with any aspect of our service or products, please advise your private wealth manager in person, in writing, by telephone or email.

How long will it take?
Our aim is to address any concerns as soon as possible and within the regulatory guidelines. The timescales we will adhere to are detailed below;

Five days
If we have been unable to resolve your complaint with you by the end of the fourth business day, we will write to you within five business days to:

• acknowledge receipt of your complaint;
• tell you who is dealing with your complaint;
• tell you how long we expect to take to resolve it.

Responding to your concerns
Should your concerns take us longer to resolve than we initially anticipated, we will contact you to update you on progress.

Within eight weeks
We will generally send you a ‘final response’ letter. This will clearly set out Firco position with regard to your complaint.

After eight weeks
In exceptional circumstances, where your complaint is particularly complex, matters may take longer than eight weeks to resolve. If this occurs, you will be advised in writing what investigation has taken place and you will be provided with a reason as to why the complaint has not been resolved.

Additionally, you will be provided with a realistic timescale as to when a final response can be expected.

Financial Services Compensation Scheme
If you make a valid claim against us in respect of anything we arrange for you, and we are unable to meet our liabilities in full, you may be entitled to redress from the Financial Services Compensation Scheme; details of the cover provided by the Scheme are available on request. Further information is available from the FCA and the Financial Services Compensation Scheme.

A summary of our internal complaints handling procedures for the reasonable and prompt handling of complaints is available on request and if you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman or by contacting them on 0800 0234 567.

We always strive to give the highest possible standards of service and recommendation.

If you wish to register a complaint, please write to Firco:

Email complaints@FircoGroup.co.uk

Or post to:
Firco
Complaints Department
62 Dunbabin Road
Childwall
Liverpool
L16 7QH

The analysis contained in this website has been procured, and may have been acted upon, by Firco and connected companies for their own purposes, and the results are being made available to you on this understanding. To the extent permitted by law and without being inconsistent with any applicable regulation, neither Firco nor any connected company accepts responsibility for any direct or indirect or consequential loss suffered by you or any other person as a result of your acting, or deciding not to act, in reliance upon such analysis. Firco, its clients, and officers may have a position or engage in transactions in any of the securities mentioned.

Firco undertakes investment research in respect of investments primarily for internal use in the portfolio management process. Upon request, some of this research material may be made available to existing private wealth management clients at the discretion of the relevant private wealth manager. Firco has in place a Conflicts Management Policy in respect of the research process. To view the conflict management policy please select the Conflict Management Policy from the drop down above or contact your private wealth manager.

You may use information on this site for your own personal reference only. You may reproduce this information in hard copy solely for your personal use. The information may not otherwise be reproduced, stored, distributed, or transmitted to any other person or incorporated in any way into another document or other material unless you first get our written permission.

To maintain the security of its systems, protect its staff and detect fraud and other crimes, Firco reserves the right to monitor all internet communications, including web and e-mail traffic, into and out of its domains. Such monitoring includes, but is not limited to, checks for viruses and other malignant code, criminal activity and use or content which breaches the Group’s internal policies. Firco also reserves the right not to deliver any communication that breaches its internal policies.

Please note that electronic mail may be monitored. The emails and the information they contain may be privileged and/or confidential. It is for the intended addressee(s) only. If you received email(s) by mistake, please let us know at info@FircoGroup.co.uk immediately and then delete it from your system; you should not copy, disclose, or distribute its contents to anyone nor act in reliance on this e-mail, as this is prohibited and may be unlawful and could in certain circumstances be a criminal offence. Firco monitors emails to ensure its systems operate effectively and to minimise the risk of viruses. Whilst it has taken reasonable steps to scan email(s), it does not accept liability for any virus that they may contain.

Communications and correspondence between you and the firm will be made in English unless otherwise agreed by you. All transactions undertaken by the Firco and instructions made by you must be provided in writing. In the interest of security, we may monitor and/or record your telephone calls with us. All instructions or requests received by telephone will be binding as if received in writing. Any recordings shall be and remain the sole property of Firco and will be accepted by the Client as conclusive evidence of the instructions/requests or conversation so recorded. The Client agrees that Firco may deliver copies of transcripts of such recording to any court, regulator or government authority.

Alternative formats
You can receive any documentation from us in the following ways, free of charge:

• Braille.
• Moon: this is a recognised system of raised shapes, similar to the print alphabet.
• Audio documents: CD, MP3, cassette or WAV, which is an uncompressed audio file for your PC.
• Translated: into any language.
• Clear and large print.
• Coloured text and/or paper: with text in any colour and on any colour paper.

If you would like to receive your correspondence in any of these formats, please let us know using the contact details shown.

Instructions
We prefer our clients to give us instructions in writing, to aid clarification and avoid future misunderstandings. We will, however, accept oral instructions provided they are confirmed in writing.

All transactions relating to the services provided by us are covered by The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017. The FCA also requires that we have appropriate measures in place to prevent the furtherance of financial crime.

Client Verification
Our responsibilities include but are not limited to verifying the identity and address of our clients and any third party making payments on their behalf. If required you must supply proof of your identity in accordance of the above Regulations. Identity verification checks may include electronic searches of the electoral roll and the use of credit reference agencies, which will result in a soft ‘foot-print’ on your credit records.

This foot-print is not visible to other financial service providers and does not affect your credit rating in anyway. In accordance with the Data Protection Act 2018 acceptance of these terms and conditions represents your permission for us to access this information.

Anti-Money Laundering
We are required by the anti-money laundering regulations to verify the identity of our clients, to obtain information as to the purpose and nature of the business which we conduct on their behalf, and to ensure that the information we hold is up-to-date. For this purpose we may use electronic identity verification systems and we may conduct these checks from time to time throughout our relationship, not just at the beginning.

Firco is not permitted to handle client money. We never handle cash and will only accept a cheque made out to us in settlement of advice and service charges. Our preferred method of payment is via bank transfer.

The authority to act on your behalf may be terminated at any time without penalty by either party giving seven days’ notice in writing to that effect to the other, but without prejudice to the completion of transactions already initiated. Any transactions effected before termination and a due proportion of any period charges for services shall be settled to that date.

In most cases you can exercise a right to cancel by withdrawing from the contract. In general terms you will normally have a 30 day cancellation period for a life, pure protection, payment protection or pension policy and a 14 day cancellation period for all other policies.

For pure protection policies the start of the cancellation period will normally begin when you are informed that the contract has been concluded or, if later, when you have received the contractual terms and conditions. In other cases, the cancellation period will begin on the day the contract is concluded or, if later, the day on which you receive the contractual terms and conditions. Instructions for exercising the right to cancel, if applicable, will be contained in the relevant product disclosure information which will be issued to you.

If you cancel a single premium contract, you may be required to pay for any loss you might reasonably incur in cancelling it which is caused by market movements. This means that, in certain circumstances, you might not get back the full amount you invested if you cancel the policy.

The ongoing service fee or our authority to act on your behalf can be cancelled at any time without any penalty, by email or post, using contact details provided. These methods ensure we have an audit trail for your instruction. You will be responsible for cancelling any instructions from your bank. If the fee is being taken from your investments we will endeavour to instruct the provider, platform or Discretionary Fund Manager to stop the fee within 5 working days of receiving your instructions and refund any overpayment if we are unable to meet this commitment.

You may ask us for an updated estimate of your advice fee at any time and you may ask us not to exceed a given amount without checking with you first.

We keep records of all our business transactions for six years and indefinitely for UK Pension Transfers. You may inspect copies of all documents on your client file. We treat all clients’ records as confidential so we reserve the right to give you copies of your particular records rather than allow access to files containing records about other clients. We maintain the highest standards of confidentiality with regard to information we hold about our clients. We shall, however, regard ourselves as authorised by you to provide information to your professional advisers and any other parties in the conduct of their business with you, unless we are notified to the contrary by you.

Investment Research
1.1 Firco business model is limited to the extent described in 1.2 and 1.3 below. Accordingly it is Firco view that the research material described below in 1.3 is offered on an independent and objective basis and such conflicts as may arise are effectively managed by the policies set out in 1.4 – 1.8.

1.2 The nature of the Firco business model is such that that the Firco does not:

• trade for its own account
• engage in corporate finance activities, or
• act as a Retail Service Provider/Market Maker.

1.3 Firco produces research, in respect of individual equities, based upon approved brokers’ research and available market information. This material is, in appropriate circumstances, available to clients upon request.

1.4 Firco operates policies of Chinese Walls and independence, which are designed to restrict the flow of information and ensure the impartiality of the research analysts e.g.

• equity research material is produced within the Research Department, which is physically, separate from, and has a separate reporting line from the private wealth management area and the portfolio advisors which are responsible for client relationships.
• equity research is produced solely from approved brokers’ research and available market information.
• staff are required to be independent when advising clients, i.e. to disregard any relationship or competing interest of which they are aware, and which could conflict with the Firco responsibility to its clients.
• research analysts are free to express their own views in research material, free from the influence or editorial control by subject companies, or by staff in any other area of Firco.

1.5 Firco has strict policies in respect of receiving gifts and inducements from suppliers of services and also in respect of personal account share dealing by members of staff.

1.6 The remuneration policy in respect of Research staff is such that there is no link between pay and reward of such staff and the volume of business transacted by Firco.

1.7 It is one of Firco objectives that all communication with clients is conducted in a manner, which is clear, fair and not misleading.

1.8 Firco has in place a clear code of conduct for staff, which outlines the principles that staff are required to adhere to in their dealings and relationships with clients.

We are committed to providing the highest standard of financial advice and service possible. The
interest of our clients is paramount to us and to achieve this we have designed our systems and
procedures to place you at the heart of our business. In doing so, we will:

• be open, honest and transparent in the way we deal with you;
• not place our interests above yours;
• communicate clearly, promptly and without jargon;
• seek your views and perception of our dealings with you to ensure it meets your expectations
• or to identify any improvements required.

Material Interest
We will act honestly, fairly and professionally known as conducting business in ‘Client’s best interest’ regulations. Occasionally situations may arise where we or one of our other clients have some form of interest in business transacted for you. If this happens or we become aware that our interests or those of one of our other clients conflict with your interest, we will write to you and obtain your consent before we carry out your instructions, and detail the steps we will take to ensure fair treatment. Where this cannot be achieved, we will not conduct the business.

Why should you read this section of the website?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This part is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date of birth, national insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

In the context of providing you with assistance in relation to your investments, savings, pensions, mortgage, finance and/or insurance requirements Your Personal Data may include:

• Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
• Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
• Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
• Any pre-existing mortgage, finance and/or insurance products and the terms and conditions relating to these

The basis upon which our firm will deal with Your Personal Data
When we speak with you about your investments, savings, pensions, mortgage, finance and/or insurance requirements we do so on the basis that both parties are entering a contract for the supply of services.

In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.

On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.

The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example your insurance or ethical investments, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance / investment providers in relation to insurance products that may meet your needs and to provide you with advice & guidance regarding the suitability of any product that may be available to you.

If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.

The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.

We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.

Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.

How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to investments, savings, pensions, mortgages, finance and insurance. You will provide information to us verbally and in writing, including email.

We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:

• Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
• Submit Your Personal Data to Product Providers, Mortgage Lenders, Commercial Lenders and/or Insurance Product providers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
• Use Your Personal Data for the purposes of responding to any queries you may have in relation to any mortgage, finance product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.

Sharing Your Personal Data
From time to time Your Personal Data will be shared with:

• Investment or pension providers Mortgage lenders, Finance lenders and/or Insurance providers
• Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our compliance advisers, product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).
• We would also like to keep you informed of pension, mortgage, insurance, investment and any other services provided by us or associated companies with which we have a formal business arrangement; which we think may be of interest to you. We would like to contact you by way of letter, email or telephone call. If you do not wish to receive such marketing information, please tick the box on Firco Service & Costs Agreement.

In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress your investments, savings, pensions, mortgage, finance and/or insurance enquiry and to provide you with our professional services.

Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

Transferring information overseas
We may transfer your information to organisations in other countries on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws.

We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area. However, in the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway).

We will only do so where:

• the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately;
• the transfer has been authorised by the relevant data protection authority; and/or
• we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission) to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses, please contact us by writing to:

in writing: The Data Protection Officer, Firco Private Clients, 62 Dunbabin Road, Childwall, Liverpool L16 7QH
Email: info@FircoGroup.co.uk
Telephone: 0151 372 0388

Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper form for a minimum period of 6 years following the advice/service you receive from us, although your data could be held for a longer period where this may be needed to meet the requirements of our regulatory bodies.

Your rights in relation to Your Personal Data
You can:

• request copies of Your Personal Data that is under our control
• ask us to further explain how we use Your Personal Data
• ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
• ask us to send an electronic copy of Your Personal Data to another organisation should you wish
• change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this section, or wish to make contact in order to exercise any of your rights set out within it please contact:
in writing: The Data Protection Officer, Firco, 62 Dunbabin Road, Childwall, Liverpool L16 7QH
Email: info@FircoGroup.co.uk
Telephone: 0151 372 0388

If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by contacting in writing: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF