Privacy & AI-Use Notice

How Pro Associate Ltd handles your personal information, including where artificial intelligence is used. This notice supplements our main Privacy Notice.

1. Who we are

Pro Associate Ltd ("we", "us") is the data controller for the personal information we hold about you.

2. What information we hold

To provide financial advice and ongoing service we hold information such as your identity and contact details, financial circumstances (income, expenditure, assets, liabilities, pensions, protection), objectives, attitude to risk and capacity for loss, meeting notes and recordings, and — where relevant to your needs — health and vulnerability information (a special category of data).

3. How we use artificial intelligence

We use AI tools to help us work more efficiently. AI never makes decisions about your finances — a qualified adviser reviews, edits and is responsible for everything produced. Specifically:

  • Drafting documents — we use Anthropic's Claude to help draft suitability reports, review packs and meeting summaries from the information in your file. The adviser checks and finalises every document.
  • Transcribing meetings — where you consent to a meeting being recorded, we use OpenAI's Whisper to transcribe the audio into text so we can capture an accurate record.

Your data is not used to train these AI models. We use them under business terms that prohibit training on our data. Meeting audio is processed in memory to produce the transcript and is not stored; the resulting transcript is kept as part of your client record. These providers may process data outside the UK (including the United States). Each processes under a written Data Processing Addendum that incorporates the EU Standard Contractual Clauses with the UK International Data Transfer Addendum, which is the safeguard we rely on for those transfers.

4. Why we can use your information (lawful bases)

5. Who we share it with

We share information only as needed to serve you — for example with product and platform providers, and with our technology sub-processors (including the AI providers named above and our hosting provider). We do not sell your data.

Our client-management and advice-drafting software is provided by Advisory Wizard Ltd (company no. 17336751), which processes your information on our behalf as our data processor under a written agreement. Advisory Wizard Ltd is registered with the Information Commissioner's Office, registration number ZC218711.

6. How long we keep it

We keep your information for as long as you are a client and for at least six years after our relationship ends. Records relating to pensions and other long-term products are kept for as long as the product remains in force and for six years beyond.

7. Your rights

You have the right to access your information, to have it corrected or erased, to restrict or object to its use, and to data portability, subject to our regulatory record-keeping duties. Where we rely on consent, you can withdraw it at any time. To exercise any right, contact us using the details in section 1. You can also complain to the Information Commissioner's Office (ico.org.uk).