Unbiased Adviser Privacy Policy

Last updated: 16th March, 2026.

Unbiased Ltd ("Unbiased," "we," "us," or "our") is committed to protecting and respecting your privacy. This policy should be read in conjunction with our Professional Terms of Use, which outline the contractual terms governing your relationship with us. This Privacy Policy applies specifically to Advisers who use the Unbiased platform and services. It explains how we collect, use, and protect your personal data when you engage with Unbiased as a subscribing or registered Adviser. Our Adviser Services are intended for financial services professionals, and we do not knowingly collect or process personal data relating to individuals under 18 in connection with them. 

1. Who We Are 

Unbiased Ltd is a company registered in England and Wales (Company No. 06775878) with its registered office at 32-38 Saffron Hill, London EC1N 8FH. We are the data controller of your personal data and responsible for its use in accordance with this privacy policy.  

Users with Multiple Roles 

If you have used Unbiased both as a consumer (e.g. by submitting an enquiry) and as an Adviser (e.g. by subscribing to our services), your data will be processed in accordance with both our Consumer Privacy Policy and this Adviser Privacy Policy, depending on the context in which the data was provided. Each role is governed by its own terms and data handling practices. 

If you have any questions about this policy, please contact our Data Protection Officer (DPO) at: 
Email: [email protected] 
Address: Data Protection Officer, Unbiased Ltd, 32-38 Saffron Hill, London EC1N 8FH 

2. What Data We Collect 

We collect and process personal data about you, including but not limited to the following: 

a. Individual Adviser Identity and Contact Information 

• Name, business name 

• Business address, email, and telephone number 

• FCA number and verification details 

b. User Account and Subscription Details 

• Username and password 

• Subscription history, usage records 

• Payment and billing information (via third-party processors) 

c. Communication and Engagement Data 

• Records of communications with our Sales, Support, and Account Management team 

• Email engagement metadata (see Section 5) 

• Call recordings between you and Unbiased (inbound and outbound, for quality, training, and compliance purposes) 

d. Platform Usage Data 

• Log-in times, clickstream data, IP address, device data 

• Actions taken within the UnbiasedPro (e.g. purchases, refund requests, pipeline usage) 

e. Marketing Preferences Information 

• Consent records, opt-in/out status, communication preferences 

f. Outcome Conversion Data 

• Contact made, meeting booked/attended, and client conversion status 

g. Client Feedback and Reviews 

• We collect reviews or feedback from consumers about their experience with you, which may include ratings, comments, and general impressions. 

We also collect, use and share Aggregated Information such as statistical or demographic data for any purpose. Aggregated Information could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your platform usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.  

We may also collect data through cookies and tracking technologies when you access the ProApp and Adviser dashboard. For more, please see our Cookie Policy. 

3. How We Use Your Data 

How your information is collected: 

• When you interact with us: you may share your personal information with us when you provide information using any means on our website, such as create an account or update your profile, or adjust your marketing preferences, or when you engage with us, or when you correspond with us by email, post, telephone or any other means. 

• From third parties: we may obtain your personal information from third parties (which, when combined with other personal information we may have of yours, may also constitute personal information). 

• Automated Technologies and Cookies: as you interact with our website, we will automatically collect platform usage data, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies. Please see our full Cookie Policy for further details. 

We may also use automation-enabled tools to support decision-making processes such as lead distribution, Adviser onboarding support, and fraud detection. These tools assist our teams but do not make decisions that produce legal or similarly significant effects without human review. For more detail on your contractual obligations, please refer to our Professional Terms of Use. 

4. How your information is used: 

Data Protection Laws require us to have a legal basis for everything that we do with your personal information falling under one of the following categories: 

• Performance of a contract with you: Where we need to perform a contract we are about to enter into or have entered into with you. 

• Legitimate interests: We may use your personal information where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and/or enable us to give you the best user experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 

• Legal obligation: We may use your personal information where it is necessary for compliance with a legal obligation that we are subject to. 

• Consent: We rely on consent only where we have obtained your active agreement to use your personal information for a specified purpose, in relation to receiving marketing emails from us. 

• Vital Interests: We may process your personal information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person. 

We use your personal information in a number of different ways and for different reasons. The tables below set out what we do and why: 

* Where we rely on your consent to process your personal data (for example, for marketing communications), you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing carried out before your withdrawal, and it will not affect processing carried out under other lawful bases, such as contractual necessity, legitimate interests, or legal obligations. 

5. Email Tracking & Engagement Analytics 

We use third-party tools, including some powered by automation technologies, to track engagement with emails sent from Unbiased, including platform updates, onboarding materials, and support communications. Where automation is used, it may assist in analysing patterns of engagement to inform future communication strategies. However, no decisions affecting you are made solely by automated means. These tools may collect: 

• Delivery, engagement and open status of emails 

• Link clicks within emails 

We use this information to: 

• Monitor and improve engagement with key materials 

• Identify support needs and improve the timing and relevance of communications 

This tracking relies on our legitimate interests under Article 6(1)(f) of the UK GDPR in ensuring that important service communications are delivered effectively and remain relevant to users. Tracking is limited to basic engagement data, such as delivery status, open rates, and link clicks, and is used solely to monitor and improve our communications. It does not involve access to your personal inbox or the content of any unrelated emails. 

6. Marketing and Service Communications 

When you register for Unbiased as a subscriber or user, we may use your contact details to send you two types of communications: 

• Service communications: Essential updates relating to your account, platform changes, or administrative matters (e.g., Terms updates, security notices). These are necessary for providing the service and you cannot opt out of receiving them. 

• Marketing communications: Occasional emails about new features, webinars, or other relevant opportunities from Unbiased. We will only send you these where we have your prior consent, or where permitted by law. You can withdraw this consent at any time by using the unsubscribe link in the email or by contacting [email protected]  

We will never share your personal data with third parties for their own marketing purposes without your explicit consent.

7. Sharing Your Data with Third-Parties 

We may share your data with third-party service providers, who support us in delivering our services. This includes providers that use automation-systems for customer support, analytics, transcription, and product optimisation. These tools may analyse behavioural patterns or preferences to help us improve our services; however, any decisions that significantly impact your access, service experience, or account status are always subject to human oversight and review. 

We also use automated tools to transcribe some inbound and outbound calls for the purposes of quality assurance, compliance monitoring, team training, and service improvement. Transcripts are stored securely and reviewed by authorised personnel and are never used for automated decision-making without human oversight. Audio files and transcripts of inbound or outbound calls between you and Unbiased are not shared with third parties. However, relevant information from these interactions may be used internally to support your account, resolve complaints, or respond to your queries. Transcripts are retained in line with our call recording retention period. 

We may also share your data with:  

• Service providers (e.g. payment processors, communication platforms, analytics tools) 

• Regulatory authorities (where required by law) 

• Professional advisers such as legal or tax advisors (for example, in relation to contractual matters between us and advisers, regulatory compliance, the establishment, exercise, or defence of legal claims, or to protect the rights or safety of the website or us);  

• Consultants, insurance companies/claim managers and accountants; and 

• Agents, suppliers or sub-contractors and other associated organisations where they are engaged by us to help deliver a service or product that we have instructed them on. 

• Third parties in case of a legal requirement. We also disclose your personal information if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process (including to law enforcement or competent authorities like the police/tax authorities, such as HMRC in the UK). 

• Third parties in case of a corporate transaction. In addition, information about our customers and users, including personal information, may be disclosed as part of any merger, sale, transfer of our assets, investment, acquisition, bankruptcy, or similar event, including while engaging with our actual or potential investors. 

• All third-party partners are contractually obligated to safeguard your data in accordance with UK GDPR.

8. International Transfers 

Whenever we transfer your personal information out of the UK or the EEA to service providers or any other third party, we ensure a similar degree of protection is afforded to it by ensuring that the necessary safeguards are in place, for example: 

• We will only transfer your personal information to countries that have been deemed by regulators in the UK or the EU to provide an adequate level of protection for personal information; or 

• We may use specific standard contractual terms approved for use in the UK and EU which give the transferred personal information the same protection as it has in the UK and EU. 

• We may also participate in the UK Extension to the EU-US Data Privacy Framework (where applicable). 

For more information about these safeguards, please contact us at [email protected]. 

9. Data Retention 

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.  For further information about specific retention periods, please contact us at [email protected]. 

These practices form part of your contractual relationship with Unbiased and should be read in conjunction with our Professional Terms of Use. 

10. Your Rights 

You have a number of rights under data protection laws in relation to your personal information. 

You have the right to: 

• Request access to your personal information (commonly known as a "subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. 

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

• Request erasure of your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. 

• You also have the absolute right to object any time to the processing of your personal information for direct marketing purposes. 

• Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

• Withdraw consent at any time where we are relying on consent to process your personal information.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

• Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in one of the following scenarios: 

• If you want us to establish the data's accuracy; 

• Where our use of the data is unlawful but you do not want us to erase it; 

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or 

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

If you wish to exercise any of the rights set out above, please contact us at [email protected] or write to our Data Protection Officer at the address listed in Section 1. 

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. 

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond 

We try to respond to all legitimate requests within one calendar month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

11. Third-Party Links 

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

12. Your Right to Complain 

You have the right to make a complaint at any time to the relevant data protection regulator.  In the UK this is the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach any regulator, so in the first instance please contact us at [email protected].

13. Changes to This Policy 

We may update this policy from time to time. If we make material changes, we will notify you via email and update the version and date on this page. 

For previous versions of our privacy policy, please contact our Support Team at [email protected]. 

If you require this privacy policy in an alternative format—such as large print, braille, or audio—or if you need additional support when contacting us, please let us know.  

Advisers who are deaf, hard of hearing, or have speech difficulties can use the Relay UK service when calling us. Simply dial 18001 followed by our phone number (if using a textphone or the Relay UK app). Relay UK is free to use; standard network charges apply for the call itself. 
 
If you ever have questions or concerns about how we use your data, we're here to help. Just get in touch via the details above.