Privacy Notice

We endeavour to provide a high quality service to all of our clients, and to deal effectively with complaints in an efficient and fair manner.

In the event of a complaint, please contact our Complaints Officer, Mr Jonathan Fry:

Telephone: 0207 1004487

We are committed to dealing with complaints in line with the Financial Conduct Authority rules, and a copy of our Complaints Procedure is available on request to clients and potential clients of Fry Family Office Ltd, free of charge.

The Financial Ombudsman Service

The Financial Ombudsman Service was established by Parliament to resolve complaints between financial businesses (including advisory firms) and their clients.

If we are unable to resolve a complaint to your satisfaction, you are entitled to refer it to the Financial Ombudsman Service, free of charge.

The contact details for the Financial Ombudsman Service are:

Tel: 0800 0234 567

Email: complaint.info@financial-ombudsman.org.uk

Web: www.financial-ombudsman.org.uk

The Ombudsman may not be able to consider your complaint if:

• What you are complaining about happened more than 6 years ago, and
• You are complaining more than 3 years after you realised (or should have realised) there was a problem.

You have six months from the date of our Final Response Letter to refer your complaint to the Financial Ombudsman Service.

If you refer your complaint to the Financial Ombudsman Service, Fry Family Office Ltd will fully co-operate with the Ombudsman and comply promptly with any requests for information regarding the complaint. 

If you accept the decision of the Ombudsman, Fry Family Office is bound by it. If, however you choose to reject the decision, you are entitled to seek redress through the courts.

Further information can be found in the Financial Ombudsman Service leaflet – 'Want to take your complaint further?'

Registered Office :
Fry Family Office Limited
42 Berkeley Square,
London,
United Kingdom,
W1J 5AW

Fry Family Office Limited is Authorised and Regulated by the Financial Conduct Authority.

FCA registration number 619767. Please visit www.fca.org.uk/register for further details.

The Company is registered in England and Wales with No. 8741581.

The Fry Family Office website is for information only and is intended to be used by persons in the United Kingdom. The content is not an offer or a solicitation to conduct investment business as defined by the Financial Services and Markets Act 2000 to persons in any other jurisdiction. The terms of use are governed by English Law. All information and material on this website is copyrighted to Fry Family Office Limited. It may be used for personal reference only.

The information on this website is provided in good faith and no representation, guarantee or warranty is made by us as to its accuracy. We shall not be liable for any loss or damage arising out of the use of or reliance on the information contained in our website. This does not affect our duty or liability to you which we have under the Financial Services and Markets Act 2000 or under the regulatory system. Fry Family Office Limited accepts no liability for information contained within websites provided by third parties that may have links to or from our website.

This notice sets out how Fry Family Office Ltd uses the personal information that we obtain, generate and process. Your personal information will be held and used in accordance with this privacy notice.

What personal information do we collect and process?

We may collect information from you whilst providing financial planning services or otherwise as a result of our dealings with you, and any individuals to whom you may be connected via personal or business relationships. The type of information we collect and process about you depends upon our relationship with you and the context in which we obtain and process your personal information.

The personal information we collect and process may include:

• your name, address and other contact details
• your occupation and interests
• the source of your wealth and information relating to your assets, investments and financial arrangements
• your attitude to investment risk, and your financial objectives
• the information included in any documents you provide to us (such as policy documents), or any online services to which you subscribe

In this notice, we refer to the information above as personal information.

We may also include special categories of personal data such as data about your health if this is necessary for the provision of our services; for example, the arrangement of a life assurance policy.

We may also collect information when you voluntarily complete client surveys or provide feedback to us.

Why do we collect and use your data?

The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data, we would also be unable to fulfil our legal and regulatory obligations.

Where special category data is required we'll obtain your explicit consent in order to collect and process this information.

How do we use your personal information?

We will primarily use your personal information in order to provide you with the services for which you engage us, which may include an ongoing review service. We may also use your personal information to:

• manage our business and our relationship with our clients
• prevent money laundering and/or terrorist financing
• undertake analysis and research to help us manage our business
• assist us to tailor our employee training plans in order to ensure our staff remain competent to provide the services we offer to clients
• provide, improve and market our services
• fulfil our legal, professional and ethical obligations

With whom do we share your personal information?

We won't share your information with any other companies for marketing purposes. If you agree, we may email you about other products or services that we think may be of interest to you.

We will share your personal information with third parties (such as the police and other law enforcement agencies) where we are under a duty to do so in order to comply with any legal, professional or ethical obligation (such as to comply with our anti-money laundering obligations), or in order to enforce or protect any of our rights, property or safety (or those of our employees or clients).

In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.

Where third parties are involved in processing your data we'll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they'll only act in accordance with our written instructions.

Where it's necessary for your personal data to be forwarded to a third party we'll use appropriate security measures to protect your personal data in transit.

The Prevention of Financial Crime

In order to comply with our obligations under the Money Laundering Regulations, we will carry out automated identification and financial crime checks, using your personal data (name, address, date of birth).

The checks will involve searching public databases such as the Electoral Register, County Court Judgements, bankruptcies and administration orders. They will also search Experian's Credit Account Information Sharing (CAIS) file. CAIS provides comprehensive and timely information about consumers' current credit commitments and payment performance histories.

In addition, checks will be performed with fraud prevention agencies, sanctions lists and the Politically Exposed Persons Database.

We may carry out further periodic checks during our relationship with you. This is to ensure that the information we hold remains correct and there has been no change in your status. We may also provide information to financial and other organisations involved in fraud prevention, to protect ourselves and our customers from theft and fraud.

Please note that the checks are identity searches, and will not leave a 'credit check footprint' on your records.

How long do we keep hold of your information?

We are subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us.

Where no client agreement has been entered into and we have not provided any recommendations to you, we will retain your personal data for a period of 2 years.

Right of Erasure - You have the right to request deletion of your personal data. We'll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

Your rights in respect of your personal information

Right of Access - If you would like a copy of some or all of the personal information that we hold in relation to you, please email or write to us, using the contact information shown below.

Right to Data Portability - If your personal data is being processed by automated means, you have the right to ask us to move your personal data to another organisation for their use, where this is technically feasible.

Right to Rectification - If you think any of the personal information we hold about you is incorrect or out of date, please contact us to correct or remove it.

Right to Restrict Processing - You have a right to block the processing of your personal data in the following circumstances:

• You have contested the accuracy of the personal data we hold and we are verifying this
• You have objected to a use of information and we are considering whether your objection is valid
• We have been unlawfully processing your information, however you wish us to continue to hold the information, instead of erasing it.

Marketing

Our Terms of Business Letter which clients sign, contains a tick-box opt in. This confirms that clients are happy to receive information from us regarding our products and services, where we feel this may be of interest to them. We do not consider consent to be indefinite, and will seek renewed consent from you after a period of 2 years.

If you have agreed to receive to receive marketing information, you may opt out at a later date by contacting us via telephone, email or post.

Cookies

We may use technology to track the patterns of behaviour of visitors to our website. This can include using a "cookie" which would be stored on your browser or the hard drive of your computing device.

Contact

If you have any queries about this policy, please let us know by contacting us at: enquiries@fryfamilyoffice.com

You can also write to us by contacting:

What can you do if you are unhappy with how your personal data is processed?

You also have a right to lodge a complaint with the supervisory authority for data protection.

In the UK this is:

Changes to our Privacy Notice

We keep our Privacy Notice under regular review and will place any updates on this page. This notice was last reviewed in May 2023.

We ask that you read the following important information carefully before you use this website. The information applies to your use of the website, and by using this website, you agree you accept these terms of use and are bound by them. If you do not agree to the proposed terms of use, we ask you to refrain from using the website. We may from time to time, update, change or refresh information and content on this website, and may do so without prior notice, hence we ask you to consult this section occasionally.

Introduction

Fry Family Office Ltd are committed to providing the highest standards and quality of financial advice. As a firm, we take the requirements of the FCA very seriously, in particular the requirement to Treat Customers Fairly (TCF). We strive to do this in respect of everything we do.

CONSUMER OUTCOMES

The FCA have listed six core consumer outcomes which explain what they expect TCF to achieve for consumers. The six outcomes are:

• Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture.
• Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
• Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
• Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.
• Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard, and as they have been led to expect.
• Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

OUR TCF PRINCIPLES

In our dealings with you, you can expect that:

• We will be open and transparent in the way we deal with you
• We will not place our interests before yours
• We will communicate clearly with you, and without the use of jargon
• We will inform you of our charges, before undertaking any work for you
• We will deal with any complaints promptly and fairly

WHEN WE GIVE ADVICE

We have a clear client proposition, and we will inform you in advance of our charges and how these should be paid.

Clients will be provided with clear information and kept appropriately informed before, during and after implementing recommendations.

When providing advice, our advisers obtain a detailed understanding of a client’s:

• Objectives (the purpose of the advice)
• Financial situation (ability to bear any risks or losses)
• Level of knowledge/expertise (ability to understand the risks)

We ensure that our clients understand the risks involved with any service or product offered and are aware of all applicable charges.

When we determine a client’s attitude to risk, we will consider the level of risk a client wants to take, balanced against the level of risk a client can afford to take (their ability to bear risk). This capacity for loss, or the ability to absorb falls in the value of their investments, will be judged against the client’s overall financial situation, and not just with reference to their investment portfolio, or a particular holding.

When assessing suitability, we will consider what the product is, the features and benefits, why it is needed and the risks involved. We will only recommend a product that is appropriate and solves a need.

We will set out in writing and in clear concise terms why we have recommended any particular investment or product.

Where appropriate and when agreed between us, we will monitor your investments and other financial products, and contact you to let you know how they are doing. In such cases, we will ensure that a product remains appropriate, continues to solve a need, and performs as originally envisaged.

If any conflicts of interest arise between us, we will tell you about this as soon as we can, after becoming aware of it.

IMPLEMENTING TCF PRINCIPLES WITHIN THE BUSINESS

As well as our dealings with clients, we also aim to include TCF principles across our business and remain committed to delivering the 6 outcomes.

Marketing

All of our financial promotions and marketing literature are reviewed to ensure that they are appropriate for the target audience and are presented in a clear, fair and non-misleading manner.

Complaints

Fry Family Office Limited seeks to maintain its reputation as a firm delivering high quality professional services. When we do receive a complaint, our primary objective is to assist in resolving it promptly, and in a fair and consistent manner. We fully comply with the rules specified by our regulator, the Financial Conduct Authority (FCA).

All complaints we receive are recorded and monitored. We also have a formal Complaints Procedure which documents how we will deal with complaints as a business. This procedure is available free of charge and at any time for all staff, clients and potential clients. We also have an internal Complaints Officer who is responsible for dealing with any complaints we receive.

The Complaints Management Function is responsible for the oversight of the investigation of complaints within Fry Family Office Limited. It is also responsible for ensuring that the Complaints Management Policy is adhered to and reviewed on an annual basis.

All complaints are reported and analysed by the Complaints Management Function, to determine whether there are any recurring or systemic problems within the business.

Breaches

We have an internal Breaches procedure and record all breaches within the Breaches Register.

As a business it is important to ensure that we are aware of when things have gone wrong, so that we can comply with our regulatory responsibilities and ensure that we are treating customers fairly.

Breaches can help us to identify training needs and procedures which may require reviewing.

Training and Competence

Our Training and Competence Scheme specifies in detail our approach to ensuring that all staff are competent and remain competent in the work that they do.

You can expect that all of our staff are trained properly for their roles, and we ensure they are appropriately supervised.

Our advisory staff are qualified financial advisers and are fully trained in respect of the investments and products they advise on. They must hold benchmark qualifications, participate in regular professional development and their competency will be assessed and monitored on an ongoing basis. This ensures that we can be certain of their competence.

Staff Awareness

Fry Family Office Ltd ensures that all advisers and staff are familiar with the fundamental principles of TCF.

All of our staff are trained to deal with clients, and receive Treating Customers Fairly training on joining the company, and then on a regular annual basis throughout their career with us.

We will remunerate and incentivise our staff in ways which encourage them to deal with our clients fairly and impartially.

Client Communications

When you contact us, you can expect that we will be polite and courteous.

When we write to you, we will be clear and straightforward. We will try not to use jargon and technical terms, and if we must use them, we will explain them in simple terms to you.

It is important that our clients realise that we are happy for them to contact us to discuss or clarify any matter with regards to the service we are providing.

Record Keeping

We have strict record keeping requirements in place for the business, and will maintain a comprehensive record of all our dealings with you in accordance with the requirements specified by the FCA. We have appropriate capacity and processing arrangements in place to ensure we are able to fulfil our obligations.

Fry Family Office clients will be permitted access to their records in accordance with our Data Protection and Security Policy.

We frequently review our policies and procedures to ensure that TCF remains an important part of our business. This is a continuous process and we do welcome feedback from our clients, so that we can improve our service.