1. Who we are
FinWELL Training Ltd (“FinWELL”, “we”, “us” or “our”) provides financial education, training and wellbeing services for organisations and individuals.
We respect your privacy and are committed to handling personal information fairly, transparently and securely. This policy explains what information we collect, how we use it, who we may share it with and the choices and rights available to you.
This policy applies to our website at www.finwell.training, our communications, events, training and digital services where we direct you to it. Some services, tools or events may provide additional privacy information relevant to that activity.
FinWELL Training Ltd is the data controller for personal information we use for our own purposes, such as managing our website, responding to enquiries and developing business relationships. In some circumstances, we may process information on behalf of an employer or another organisation; where this applies, that organisation’s privacy information may also be relevant.
Contact us about privacy: support@finwell.training
ICO registration number: ZB500112
2. What personal information means
Personal information is information that identifies you, or could reasonably be used to identify you, either on its own or together with other information.
Information is not necessarily anonymous simply because your name or email address has been removed. We consider whether someone could reasonably be identified, including through combinations of information, before describing data as anonymous.
3. Information we may collect
The information we collect depends on how you interact with FinWELL.
Website visitors and people who contact us
We may collect:
• Your name, email address, telephone number, organisation and job title when you provide them.
• The contents of your enquiry, correspondence or feedback.
• Technical and usage information, such as your IP address, browser type, device information, pages visited and referring website, where this is collected by our website or service providers.
• Your communication and marketing preferences.
Clients, suppliers and business contacts
We may collect:
• Your name, job title, employer or organisation and professional contact details.
• Information about your professional responsibilities and your organisation’s interests or requirements.
• Records of meetings, enquiries, proposals, contracts, invoices and communications.
• Information relevant to managing our relationship, such as the source of an introduction, follow-up actions and your communication preferences.
Event and training participants
Depending on the activity, we may collect:
• Your name, organisation, contact details and registration information.
• Attendance, participation and completion information.
• Feedback, survey responses and information you choose to share with us.
• Access or support requirements you choose to tell us about.
Please avoid sharing sensitive personal information unless it is necessary for the support you are requesting. We will explain if we need such information and how it will be handled.
Users of FinWELL tools and learning services
Our digital tools and learning services may collect responses, results, preferences, learning progress and feedback. The information requested depends on the individual tool.
Some activities are designed so that you do not need to provide your name or email address. Where we describe a particular tool or response as anonymous, we will explain what is collected and how the information may be used or reported. Other services, such as account-based learning or one-to-one support, may require identifiable information.
Please check the information shown at the start of each tool or activity. We do not ask you to provide account passwords, bank account numbers or other financial credentials in the FinWELL Money Score.
Sensitive information
Some information about your health, disability, ethnic background or other protected characteristics is classed as special category data under data protection law. Information about your financial circumstances is not automatically special category data, but it can still be sensitive and should be treated carefully.
If we need to use special category data, we will identify an appropriate lawful basis and a separate condition under data protection law. Where we rely on your explicit consent, we will explain this and how you can withdraw it.
4. Where we obtain information
We may receive information:
• Directly from you, for example when you complete a form, contact us, attend an event or use a service.
• From your employer or another organisation arranging training or support, where appropriate.
• From a colleague, business contact or partner who introduces us.
• From publicly available professional sources, including organisation websites, professional networks, Companies House and public event information.
• From business information providers, such as Lusha, where we use their services to research relevant organisations and professional contacts.
• From our website, event, communications and service providers when you interact with our services.
When we obtain personal information from another source, we provide privacy information within the period required by law, including when we first communicate with you where that occurs sooner.
5. How and why we use information
We only use personal information when we have a lawful basis to do so. The main purposes and bases we expect to use are set out below.
Responding to enquiries and taking steps at your request before entering into a contract: Taking steps before a contract, or our legitimate interests in responding to enquiries and managing our business relationships.
Providing and administering training, events, accounts and other services: Performance of a contract where the contract is with you; otherwise, our legitimate interests in delivering and administering our services.
Managing business relationships, proposals and professional contacts, including through the FinWELL Growth Hub: Our legitimate interests in operating and developing our business, provided these are not overridden by your rights and interests.
Sending relevant business-to-business communications and marketing, where permitted: Our legitimate interests in promoting our services, or consent where we rely on it; electronic marketing rules also apply separately.
Sending marketing where consent is required or chosen as our basis: Your consent, which you can withdraw at any time.
Maintaining security, preventing misuse and improving our services: Our legitimate interests in protecting and improving our services, subject to the appropriate safeguards.
Keeping accounting records and meeting other applicable legal requirements: Compliance with a legal obligation.
Handling complaints, exercising rights and establishing or defending legal claims: Our legal obligations or legitimate interests, depending on the circumstances.
Where we rely on legitimate interests, we consider the purpose, whether the use is necessary and whether your interests, rights and reasonable expectations outweigh ours. You may object to processing based on legitimate interests; see section 12.
If we need to use information for a materially different purpose, we will provide further information where required.
6. FinWELL Growth Hub and business outreach
We use the FinWELL Growth Hub to help us manage professional relationships, enquiries, sales opportunities, follow-ups and client communications.
The information held may include your name, organisation, job title, work contact details, professional profile link, how we found or were introduced to you, notes relevant to our relationship, communications history, follow-up actions and any marketing preferences or objections.
We may research professional contacts using information you provide, introductions, publicly available professional sources and business information providers such as Lusha. We use this information to identify relevant contacts and understand whether FinWELL’s services may be of interest to their organisations.
Where permitted, we may contact you in your professional capacity about financial wellbeing education, training, events, campaigns or related services. We aim to make our communications relevant and proportionate.
You can object to direct marketing at any time. You can do this by replying to a message, using an unsubscribe option where provided, or emailing support@finwell.training. If you object, we will stop using your personal information for direct marketing. We may retain a limited record of your details and preference on a suppression list so that we can respect your request.
We apply the relevant rules to the communication channel and the recipient. For example, different electronic marketing rules apply to corporate organisations and to sole traders or certain partnerships. We do not treat the public availability of contact details as permission to send marketing.
7. Money Score, personality tools and employer reporting
FinWELL uses tools and learning activities to help people reflect on financial wellbeing, identify areas for support and access educational resources.
Where an employer or other organisation commissions a programme, we may provide reporting on participation, themes and outcomes. Depending on the activity, reports may include aggregated results, trends or feedback.
We aim to present employer reporting in a way that protects individuals’ privacy. We assess the risk of identification, including where groups are small or several characteristics are combined, and apply appropriate safeguards. We do not promise that every dataset is anonymous without assessing how the particular tool works and what information is collected.
The information displayed within each tool or activity will explain what is collected, whether identifying information is requested and how results may be used. If a service involves identifiable participation, account access or individual support, we will make that clear.
FinWELL provides financial education and guidance. We do not provide regulated financial advice.
8. Who we share information with
We may share information where appropriate and necessary with:
• Service providers that support our website, hosting, communications, customer relationship management, event delivery, online meetings, learning services, payments, analytics, security or business operations.
• Trainers, professional advisers and delivery partners involved in providing the services you or your organisation have requested.
• An employer or commissioning organisation, where this is appropriate for the agreed service and consistent with the information given to participants.
• Regulators, law enforcement bodies or other authorities where required or permitted by law.
• Professional advisers, insurers or other parties where necessary to establish, exercise or defend legal claims.
• A prospective buyer or successor if our business is reorganised or transferred, subject to appropriate confidentiality and legal safeguards.
Service providers acting on our behalf are required, where applicable, to use personal information only for agreed purposes and under appropriate contractual protections.
We do not sell personal information as a standalone product. Where a third party operates its own service as an independent controller, its own privacy information may also apply.
9. International transfers
Some of our service providers may store or access information outside the UK. Where UK data protection law restricts such a transfer, we use an appropriate transfer mechanism or safeguard, such as a UK adequacy decision or suitable contractual protections, where required.
You can contact us for more information about the safeguards that apply to a particular transfer.
10. How long we keep information
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including to provide services, maintain business records, comply with legal obligations, resolve disputes and enforce agreements.
The period depends on the nature of the information and our relationship with you. When deciding how long to retain it, we consider:
• Whether our relationship or the service is ongoing.
• Whether we need the information for a relevant legal, tax, accounting or regulatory requirement.
• Whether it may be needed to address a complaint or legal claim.
• Whether it remains relevant and accurate.
• The need to retain limited information to honour an objection or unsubscribe request.
We periodically review information and delete or anonymise it when it is no longer needed, subject to any applicable retention requirements. You can ask us for more information about the retention period or criteria that apply to your information.
11. Security
We use appropriate technical and organisational measures intended to protect personal information against unauthorised access, loss, misuse or disclosure. These measures are selected with regard to the nature of the information, the risks involved and the systems used.
No method of transmission or storage can be guaranteed to be completely secure. If a personal data breach occurs, we will assess it and notify the ICO and affected individuals where required by law.
12. Your rights
Depending on the circumstances and applicable law, you may have the right to:
• Request access to your personal information.
• Ask us to correct inaccurate or incomplete information.
• Ask us to erase your information.
• Ask us to restrict how we use your information.
• Object to processing based on legitimate interests.
• Receive certain information in a portable format or ask us to transfer it.
• Withdraw consent where we rely on consent.
• Object at any time to the use of your personal information for direct marketing, including related profiling.
Some rights are subject to conditions or exceptions. Withdrawing consent does not affect processing that took place lawfully before withdrawal.
To exercise a right, email support@finwell.training. We may need to verify your identity or ask for information to help us locate the relevant records. We will respond within the applicable legal timeframe.
You also have the right to complain to the Information Commissioner’s Office at ico.org.uk. We would welcome the opportunity to address your concerns if you contact us first, but you are not required to do so.
13. Cookies and similar technologies
Our website and some of our service providers may use cookies or similar technologies to make services work, remember preferences, understand usage or support other functions.
Where required, we will ask for your consent before placing or accessing non-essential cookies or similar technologies. You can manage your choices through the cookie controls made available on the relevant website or service and through your browser settings.
Further details should be provided in our cookie information or cookie settings, including the types of cookies used and how to change your preferences.
14. Links to other websites and services
Our website and learning resources may link to websites or services operated by other organisations. Those organisations have their own privacy practices, and we encourage you to read their privacy information before providing personal information.
15. Children and young people
Our services are intended for the audiences specified for each programme. Some FinWELL tools, including those that state they are for people aged 16 and over, are not intended for children under 16.
Where we provide an activity involving younger participants, we will assess the appropriate safeguards and provide relevant privacy information for that activity.
16. Changes to this policy
We may update this policy when our services, practices or legal requirements change. The current version will be available on this page, with its date of last update. Where appropriate, we will provide additional notice of significant changes.
Last updated: 28 October 2026