Privacy policy

Who we are

Life Adviser is a trading style of PJG Financial Limited, a company registered in Scotland under company number SC535782, with its registered office at 5 South Charlotte Street, Edinburgh EH2 4AN. PJG Financial Limited is authorised and regulated by the Financial Conduct Authority under firm reference number 919697, and is registered with the Information Commissioner’s Office under registration number ZB537016.

Life Adviser is an introducer. We do not give advice and we do not arrange insurance policies. When you send us an enquiry through this website, PJG Financial Limited deals with it: we may pass it to one adviser firm that can help, and that firm contacts you, as explained below. If no firm can take your enquiry when you send it, we may still pass it to one that can in the 30 days after you send it. PJG Financial Limited also runs Protection Connect, our own system for introducing enquiries to adviser firms. In this policy, “we”, “us” and “our” mean PJG Financial Limited, trading as Life Adviser.

Information we collect

What our quote form asks for

When you send us an enquiry using our quote form, we receive:

• who you would like cover for (just you, or you and your partner)
• if the cover is for you and your partner: your partner’s age and whether they have smoked or used nicotine in the last 12 months. We do not ask for your partner’s name or contact details
• how much cover you would like and for how long
• your age
• your first name and last name
• your postcode
• your phone number and email address
• the short notice we show you before you send the form, which explains that we may pass your details to one FCA-authorised adviser firm, the name of that firm if we have found one for your answers, and, if you tick the optional box, your agreement to receive marketing. For each one we record the exact wording, its version, and the date and time
• the page you sent the form from, the date and time you sent it, and a reference number starting “LA-” that we give your enquiry
• how you found us, where the link you followed or your browser tells us: the advert you clicked (the Google Ads campaign, ad group, ad and keyword, the type of device, and the click reference Google adds to the link), or the website that sent you, and the first page you visited on our website and when you arrived. We carry these details in the web address as you move between our pages. We do not store them on your device

If we pass your enquiry to an adviser firm, the firm may later tell us whether it reached you, whether it gave you a quote, and whether you took out cover and, if you did, how much it costs (the premium). We keep this with your enquiry.

When the form is sent, our website host may also record technical information with it, such as your IP address and browser type, to help keep out spam and misuse.

If you use the calculator on the form to help choose an amount of cover, the figures you enter there are not sent to us. Our quote form does not ask about your medical history.

If you email or call us, we will use the information you give us to deal with your request.

Your smoking status

Our quote form asks whether you have smoked or used nicotine in the last 12 months, including vaping, e-cigarettes and nicotine replacement products. Insurers price life insurance differently for smokers and non-smokers, so knowing this helps the adviser firm talk through realistic options with you.

We treat your answer as health information, which is special category data under UK data protection law. We use it to deal with your enquiry, and we may share it with the adviser firm we introduce you to, because it is needed to arrange life insurance. The law allows this without your consent: we rely on Article 9(2)(g) of the UK GDPR (substantial public interest), using the insurance condition in paragraph 20 of Part 2 of Schedule 1 to the Data Protection Act 2018, and we keep the appropriate policy document that the Act requires.

If you ask for cover for you and your partner, the form also asks whether your partner has smoked or used nicotine in the last 12 months. We treat and protect your partner’s answer in the same way as yours, on the same basis. Please only give it if your partner is happy for you to, and show them this policy.

How we use your information and our lawful bases

Under data protection law, we must have a lawful basis for each way we use your personal information. We use it:

• To deal with your enquiry. We record your answers and use them to look for an adviser firm that can help you, as explained below. We rely on this being a step you have asked us to take before you might take out a policy, and on our legitimate interest in dealing with the enquiries people send us. We also keep a record of the notice we showed you on the form.
• To introduce you to an adviser firm. We pass your enquiry to one FCA-authorised adviser firm, as explained below, because you have asked for help with life insurance. We rely on this being a step you have asked us to take, and on our legitimate interest, and the firm’s, in putting you in touch with a firm that can arrange cover.
• To use and share your smoking status. We rely on the insurance condition described above (UK GDPR Article 9(2)(g) and paragraph 20 of Part 2 of Schedule 1 to the Data Protection Act 2018), together with the reasons above for dealing with your enquiry and introducing you.
• To send you marketing. Only if you tick the optional marketing box. We rely on your consent.
• To run and protect our website and forms, including keeping out spam and misuse. We rely on our legitimate interests.
• To keep records and meet our obligations, for example when dealing with a complaint or meeting the rules that apply to us as a regulated firm. We rely on our legal obligations, and on our legitimate interest in being able to show what happened and to deal with any legal claims.
• To check which adverts, websites and kinds of enquiry lead to people getting cover. We use how you found us, and what the adviser firm tells us about your enquiry, to judge the quality of the enquiries we introduce, to decide where to advertise and to work out what an introduction is worth. We do not use your smoking status for this, and we do not pass these details to Google or any other advertiser. We rely on our legitimate interests. You can object at any time (see Your rights).
• To measure our advertising with Google’s tag. Only if you click “Accept all” on our cookie banner, as explained under Cookies below. We rely on your consent.

Our quote form only accepts enquiries from people aged 18 to 80, and checks this from the age you enter. Protection Connect chooses which adviser firm to pass your enquiry to automatically, as explained below. We do not make any decision that has a legal or similarly significant effect on you using only automated means.

Companies that handle your information for us

We use a small number of service providers. They handle your information on our behalf, to provide their services to us.

• Netlify (Netlify, Inc.) hosts this website and receives and stores the enquiries sent through our quote form. It emails us a notification of each new enquiry, containing your contact and cover details (and your partner’s age, if you asked for cover for you both) but not any answer about smoking. Netlify is a US company, so your information may be transferred to and processed in the United States.
• Krystal Hosting provides our email service in the UK. Enquiry notifications, and emails you send us or we send you, are stored there.
• Supabase (Supabase, Inc.) stores the Protection Connect database on servers in London. Enquiries we pass to an adviser firm, and enquiries no firm has taken yet, are kept there.
• Resend (Plus Five Five, Inc.) sends Protection Connect’s emails, including the email that passes your enquiry to an adviser firm if that firm has chosen to get enquiries by email. Resend is a US company, so those emails are stored in the United States.
• Twilio (Twilio Inc.) connects calls to our 0800 number and stores any call recordings we make. Twilio is a US company, so your phone number and any call recordings may be transferred to and processed in the United States.
• Data8 (Data8 Limited), a UK company, checks that the phone number and email address you enter in our quote form are real and can be reached, to help make sure adviser firms receive genuine enquiries. It receives only your phone number and email address, not the rest of your enquiry.

If you would like more information about how your information is protected when it is processed outside the UK, please contact us.

Adviser firms, insurers and other organisations

When you send us an enquiry, we may pass it to one FCA-authorised adviser firm, or one of its appointed representatives, that can help you with life insurance. We find that firm through Protection Connect, which is run by PJG Financial Limited. Protection Connect chooses the firm automatically, from firms we have checked on the FCA register whose criteria match your enquiry. Where more than one firm fits, the fee a firm has agreed to pay us can affect which one is chosen.

If no firm can take your enquiry when you send it, we keep it in Protection Connect, with your contact details, so that we can pass it to an FCA-authorised adviser firm, or one of its appointed representatives, that can help. If a firm can take it in the 30 days after you send it, we pass it on as described here, and that firm will contact you. After those 30 days we delete your contact details from Protection Connect and do not pass your enquiry on. We keep and then delete the rest of your enquiry as explained under “How long we keep your information” below.

We send that firm your name, phone number, email address, postcode, age, the cover you asked about and your smoking status. If the cover is for you and your partner, we also send your partner’s age and smoking status. Protection Connect also records your IP address and browser type when your enquiry is passed on, to prevent misuse and to show that you were shown this policy before you sent the form.

That firm gives any advice and arranges any cover, and pays us a fee for the introduction. This costs you nothing extra. Once it has your details, the firm is responsible for how it uses them under its own privacy notice. If we have found a firm for your answers, we show you its name before you press Get my quotes, and it will tell you who it is when it contacts you. If you would like to know which firm has your details, contact us.

If you answer our questions but stop before sending your phone number and email address, Protection Connect will already have used your answers (never your name or contact details) to find a firm, and may have shown you its name. The firm is told nothing about you. Within 24 hours we delete those answers and the details of how you found us, such as the advert you clicked. All we keep is a short note that does not identify you: when you used the form, the type of cover, whether it was for one person or two, the first part of your postcode (for example SW1A), the general source of your visit (for example, a Google advert) and the result of our search for a firm. We delete that note after 6 years.

We do not share your details with any other broker, insurer or adviser firm, and we do not sell lists of personal data.

We may also have to share information when the law requires it, for example with our regulator, the Information Commissioner’s Office, the Financial Ombudsman Service if you refer a complaint to it, or the police.

If you phone us

When you call us on 0800 007 4945, we connect your call straight to one FCA-authorised adviser firm, or one of its appointed representatives, that can help with your enquiry. We find that firm through Protection Connect, in the same way as for enquiries sent through our quote form, and we may pass your phone number to that firm.

When we put your call through to an adviser firm, we record the first minute of the conversation, both you and the firm. We do this so we can check that the call was answered and was a genuine enquiry if the firm asks for its fee back, and to deal with any complaint about the call. We don’t record the rest of the call, and we don’t transcribe or analyse recordings. Only our compliance staff can listen, and only to settle a question about that call. We delete recordings after 30 days, unless we need one for longer while a claim, a complaint or your own request about the call is open. Twilio, our phone provider, stores recordings for us in the United States, with safeguards for your information. If you mention your health, we take extra care with it and use it only for these purposes. If you would rather not be recorded, you can use the enquiry form on our website instead. The adviser firm may also record calls under its own privacy notice.

You may talk about your health in the first minute of a call, so a recording can include health information. The law allows us to keep and use it without your consent: we rely on Article 9(2)(g) of the UK GDPR (substantial public interest), using the insurance condition in paragraph 20 of Part 2 of Schedule 1 to the Data Protection Act 2018, and, where we need a recording for a complaint or dispute, on Article 9(2)(f) (legal claims). We keep the appropriate policy document that the Act requires.

We rely on the same lawful bases as when we pass on an enquiry from our quote form: this is a step you have asked us to take, and we and the firm have a legitimate interest in putting you in touch with a firm that can arrange cover. When we record the first minute of a call, we rely on our legitimate interest in checking that the call was answered and was a genuine enquiry, and in dealing with complaints and disputes about it.

How long we keep your information

We keep your enquiry, and any messages you send us, for 2 years from the date you send them, and then delete them. This applies to:

• the enquiry you send through our quote form, including the record of your contact and marketing choices
• your smoking status, and your partner’s, if you gave them
• the copy of your enquiry kept in Protection Connect. If no adviser firm took your enquiry, we delete the contact details in that copy 30 days after you sent it
• emails you send us, and any notes we make of calls with you
• the email notifications we receive when you send an enquiry
• how you found us, and what an adviser firm told us about the outcome of your enquiry. The click reference Google adds to an advert link is deleted after 90 days

Answers from a quote form you did not send are deleted within 24 hours, as explained above.

If we pass your enquiry to an adviser firm, we also keep a record of the introduction (which firm, when, our reference and the version of this policy), without your name or contact details, for 6 years from your enquiry. We need it to meet our obligations as a regulated firm and to deal with any complaint. The firm keeps its own copy of your details under its own privacy notice.

If you phone us on 0800 007 4945, we keep your phone number for 90 days and then delete it, including from our phone provider’s call records, and we keep the recording of the first minute of your call for 30 days, as explained above. We keep a record of the call (when it was, how long it lasted and which firm took it) for 6 years, for the same reasons as the record of an introduction.

We will delete your details sooner if you ask us to, unless we have to keep something by law. If we do, we will tell you what we are keeping and why.

Marketing

We only send you marketing if you tick the optional box on our quote form: “Keep me up to date with offers from Life Adviser by email. I can unsubscribe at any time.” We only send marketing by email. Leaving the box unticked does not affect your enquiry. We record the wording, its version, the date and time, and the page where you agreed.

You can stop marketing at any time by emailing contact@lifeadviser.co.uk. Any marketing email we send you will include a way to unsubscribe.

Cookies and Google Ads

Our cookie banner lets you choose “Reject all” or “Accept all”. We set one essential cookie to remember your choice for 180 days.

If you click “Accept all”, some pages of our website load Google’s advertising tag (Google Ads). Google can then set cookies and receive information about your visit, such as your IP address, device and the pages you view, which helps us measure and improve our adverts. Google uses this information under its own privacy policy. If you click “Reject all”, or make no choice, the tag does not load. We do not send Google the details you enter in our quote form.

To change your choice, delete the cookies for our website in your browser settings. The banner will then appear again. You can find out more in our cookie policy.

Your rights

Under data protection law, you have the right to:

• ask for a copy of the personal information we hold about you
• ask us to correct information that is inaccurate or incomplete
• ask us to delete your information
• ask us to restrict how we use your information, or object to how we use it. You can object to marketing at any time
• ask us to transfer information you gave us to you or to another organisation
• withdraw your consent at any time, for example for marketing. This does not affect anything we did before you withdrew it

To use any of these rights, contact us using the details below. It is free, and we will normally reply within one month. We may need to check your identity first. If we have already passed your details to an adviser firm, we will pass your request on to that firm.

Keeping your information secure

Our website uses an encrypted (HTTPS) connection, so the details you send through our quote form are encrypted on their way to us. We use appropriate technical and organisational measures to protect your information, including limiting who can access it. No system can be completely secure, but we take security seriously.

Links to other websites

Our website may contain links to other websites. We are not responsible for their privacy practices or content.

Changes to this policy

We will update this policy when the way we use your information changes. The date and version at the top of this page show when it last changed. The latest version is always available here on our website.

Contact us

If you have any questions about this policy, or wish to use your rights, you can email contact@lifeadviser.co.uk or write to PJG Financial Limited, 5 South Charlotte Street, Edinburgh EH2 4AN.

Complaints

If you are unhappy with how we have handled your information, please contact us first so we have the chance to put things right. Our complaints procedure explains what happens next.

You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection, at ico.org.uk or on 0303 123 1113.