Who we are
Sustain Momentum Ltd is the data controller for the information described in this notice.
- Registered in England and Wales, company number 16090278
- Registered office: 27 Westcoombe Avenue, London SW20 0RQ
- Email: info@sustain-momentum.com
- Registered with the Information Commissioner’s Office, registration number ZB967406
We are not authorised or regulated by the Financial Conduct Authority.
What we collect
If you only visit this website, we collect very little:
- What you type into a contact form or send us by email — your name, your email address, your telephone number if you give it, the content of your message, and a record of your consent
- Technical information our hosting provider needs in order to deliver the site and keep it secure, including your IP address, your browser type and the pages you asked for
If you agree to it in our cookie banner, we use Google Analytics to understand how the website is used — for example which pages are read, whether our videos are watched and whether the contact form is used. It does not receive what you type into the form. We do not use advertising tools or marketing pixels on this website.
Our “How much is enough?” calculator works in your browser. The figures you enter and the results it shows are not sent to us and are not stored by us. If you print or save your results, that copy stays with you.
If we work together, we collect what the work needs. This will usually include:
- Your contact details, and those of anyone you ask us to deal with
- Information about your financial position — income, expenditure, property, pensions, investments, borrowing, insurance, business interests
- Documents you give us, or that you authorise someone else to give us
- Information about your circumstances, your family, your plans and what matters to you
- Records of our conversations, our notes, and the documents we prepare for you
Information about other people
This is the part most people do not expect, so we set it out plainly.
Financial planning is rarely about one person alone. To help you, we will often need information about other people — a spouse or partner, children, a former partner, a business associate, an executor, someone with an interest in a property.
We collect that information from you, not from them. We ask you only for what the work genuinely needs, and we ask you not to give us more than that.
When we tell that person. Data protection law expects us to tell someone when we hold information about them. We will normally ask you to tell them, or we will tell them ourselves, within a month. We will not do so only where the law allows it — for example where they already have the information, where telling them would be impossible or would involve disproportionate effort, or where it would be likely to make impossible or seriously impair the purpose you have asked us to help with. In those cases we take other steps to protect their interests, including publishing this notice. If we decide not to tell someone, we will record why, and we will tell you.
Sensitive information. Some information is treated as special category data — for example anything about health, or anything from which beliefs or origins could be inferred. Financial conversations sometimes touch on it: an illness that affects when someone can retire, a need to provide for a person who is vulnerable. We would rather you told us only what is necessary. Where we do hold such information, we hold it because you have given us your explicit consent, or because it is needed to establish, exercise or defend a legal claim. You can withdraw that consent at any time, and we will explain what that means for the work.
Why we use it
| What we are doing | Our lawful basis |
|---|---|
| Replying to an enquiry you sent us | Our legitimate interests in responding to the enquiry you sent us, or steps taken at your request before entering a contract where that applies |
| Carrying out work you have engaged us to do | Performance of our contract with you |
| Preparing to work together — a proposal, a scope, a fee quote | Steps taken at your request before entering a contract |
| Keeping a record of our work, for our own protection and yours | Our legitimate interests in being able to show what we did and why |
| Operating and securing this website | Our legitimate interests in keeping the site working and safe |
| Measuring how the website is used, with Google Analytics | Your consent, given in our cookie banner. You can withdraw it at any time using the “Cookie settings” link at the foot of every page |
| Keeping records the law requires us to keep | Legal obligation |
| Anything involving special category information | Your explicit consent, or the establishment, exercise or defence of legal claims |
We do not sell your information, and we will not add you to any marketing list without asking you first.
Sharing with other professionals
Part of what we do is help you work with specialists — a solicitor, an accountant, a tax specialist, a valuer, or an FCA-authorised firm.
We do not pass your information to any of them unless you ask us to, in writing. When you do, we may prepare factual briefing material describing your position and send it to the person you have named. You contract with them directly and you pay them directly. We receive no commission, introduction fee or benefit of any kind from anyone we mention to you, whether or not you go ahead.
We may also share information where the law requires it, or with our own solicitors, accountants and insurers if we ever needed to defend a claim.
Technology we use, including AI
We use ordinary business software to do our work: website hosting, email, document storage, scheduling and accounting. Those suppliers process information on our instructions, under written contracts, and some of them operate outside the UK under approved safeguards.
If you accept analytics cookies, Google Analytics, provided by Google, processes information about your visit on our behalf: the pages you view, roughly where you are, derived from your IP address, your device and browser, and the interactions described in our Cookie Notice. Google says it does not log or store IP addresses from visitors in the UK, EU or Switzerland. We have switched off Google’s advertising features and do not share this data with Google for its own purposes. Google may process this information in the United States; see “Where your information is held”.
We also use artificial intelligence tools to help us work — for example to organise information, prepare drafts, summarise documents and check our own thinking. We think you should know exactly where the limits are:
- A person makes every decision and reviews everything that reaches you. No AI tool decides anything about you, and nothing we send you is produced without a human reading it first
- There is no automated decision-making of the kind that produces legal or similarly significant effects for you, and no profiling of that kind
- We use paid business-tier services whose terms do not permit your information to be used to train their models, and we check that position when we adopt a tool and when a supplier changes its terms. If we could not get that assurance from a supplier, we would not put information that identifies you into it
- We minimise what goes in. Wherever the work allows it, we remove names and identifying detail first
If you would prefer us not to use AI tools on your information at all, tell us and we will work without them. It may make some things slower; it will not affect the quality of what you get, and we will not charge you more.
How long we keep it
| What | How long |
|---|---|
| Enquiries that do not lead to us working together | Up to 24 months, then deleted |
| Client files — our notes, the documents we prepared, and the record of what you asked for and what we did | Six years from the end of our work together, and longer where a matter is still live or a claim is possible |
| Records we must keep by law, including accounting records | Six years, or the period the law requires |
| Website server logs | A short period set by our hosting provider, for security |
| Website analytics user and event data, only if you accept analytics cookies — records of individual visits and actions linked to an analytics cookie | Our retention setting is 2 months. Google deletes data older than that through its monthly deletion process |
| Aggregated website analytics reports — combined figures such as page views per month, which do not identify you | Kept in our Google Analytics account for as long as we use it; not affected by the 2-month setting |
Why six years. It is the ordinary limitation period for a contract claim in England and Wales. Keeping the file for that period protects you as much as us — if a question ever arose about what was said or decided, the record is what answers it.
Where your information is held
Your information is held in the UK and the European Economic Area wherever we can arrange it. Some of our suppliers operate elsewhere. Where information goes outside the UK, we rely on the safeguards UK data protection law provides for — an adequacy decision, or the International Data Transfer Agreement or Addendum. You can ask us which suppliers these are and we will tell you.
Google Analytics data may be processed by Google in the United States. Google LLC is certified under the UK Extension to the EU–US Data Privacy Framework, which UK law recognises as giving adequate protection. Where that does not apply, Google relies on the contractual safeguards in its data processing terms.
Keeping it safe
We use reputable suppliers, keep our software up to date, protect our accounts with strong authentication, and limit access to information to what is needed. No system is perfect, and we would tell you promptly if something went wrong in a way that affected you.
Your rights
You can ask us to:
- Give you a copy of the information we hold about you
- Correct anything that is wrong
- Delete information, where there is no good reason for us to keep it
- Restrict what we do with it while a question is resolved
- Object to us using it where we rely on our legitimate interests
- Send it to you, or to someone else, in a portable format, where that right applies
- Withdraw your consent, where consent is what we relied on
Ask us by emailing info@sustain-momentum.com. We will respond within one month. There is no charge. We may need to check who you are first.
Some rights do not apply to everything — for example, we may need to keep a record for the six-year period above even if you ask us to delete it. If we cannot do what you have asked, we will tell you why.
If you are not happy
Please tell us first — info@sustain-momentum.com. We would rather fix it.
You also have the right to complain to the Information Commissioner’s Office at any time: ico.org.uk/make-a-complaint or 0303 123 1113. Complaining to us first does not affect that right.
Cookies
This website uses a small number of cookies. Our Cookie Notice explains which, and why.
Changes to this notice
We will update this notice when what we do changes. The date at the top tells you when it last changed. If a change materially affects how we use information about you, we will tell our clients directly rather than rely on you noticing.