Your rights, your information and how we use it.
LifeStage is committed to protecting your personal identifiable information (PII). This Privacy Policy explains what personal data we collect, how we use it, who we may share it with, why, and your rights and choices regarding your data. Whether we collect data for our services or about our staff, all personal details—however collected, recorded, or used, regardless of the media—have appropriate safeguards applied in line with the Data Protection Act 2018 and UK data protection legislation.
We may update this Privacy Policy periodically. Please check our website for the latest version or contact us. We will notify you of significant changes via email or other appropriate channels.
Who we are
LifeStage is a trading style of WPS Advisory Limited. WPS Advisory Limited is authorised and regulated by the Financial Conduct Authority (FCA) for regulated advice (FCA Reference Number: 624546). You can verify this at https://register.fca.org.uk or by contacting the FCA at 0300 500 8082.
We act as data controllers and processors under the Data Protection Act 2018. As a data processor, we receive personal data from third parties (data controllers). It is your responsibility to keep your personal data accurate and current by informing us of any changes during our relationship.
All information, including PII, is encrypted. Sensitive data transmitted over public networks is protected using encryption techniques such as VPN, SSL, and IPSEC.
How to contact us
For questions about this Privacy Policy or your data, contact:
The Data Protection Officer
WPS Advisory Limited
Suite A, 5th Floor, West One,
Newcastle upon Tyne
NE1 3PA
Email: dataprotectionenquiries@wpsadvisory.com
A copy of our Privacy Notice is available at https://lifestageadvice.com/privacy/. Contact us to request a copy. Please allow one month for our response.
The information we collect and use
- Information about you, e.g., name, address, contact details, gender, date of birth, National Insurance number, pension reference number, benefits details, service periods, and, if employed and an active pension scheme member, salary details.
- information connected to your product or service with us e.g. your bank account details
- for WPS LifeStage Money App subscriptions, payment data (e.g., billing details) processed via the Apple App Store or Google Play Store, which issue digital receipts to your registered email or app account.
- for App users, data processed through our technology partner, Moneyhub, to provide financial information services; data related to two-factor authentication (2FA) methods (e.g., authenticator apps, SMS codes); and device-related data (e.g., operating system version) to ensure functionality on compatible devices (Apple iOS 15.1 or later, Android 7.0 or later).
- information from your interactions, e.g., forms on our website, posted material, service requests, meetings, recorded phone calls (including voice elements of video calls), emails, letters, questionnaires, fact finds, and details about family, lifestyle, social circumstances, and financial status.
- automatically collected data, e.g., via cookies when visiting our websites.
- access data for online services, e.g., name, email address, date of birth, National Insurance number.
- special category data, e.g., health, marital or civil partnership status, collected only with your consent for specific products or to comply with legal obligations.
- information about others you provide (e.g., spouse, partner, dependants over 13), where you are responsible for obtaining their consent for our use per this Privacy Policy.
- the App is restricted to users aged 18 and over, and we do not collect data on children through the App. For other services, we may collect limited data on children (e.g., dependants) only to identify their relationship with you, with communication directed to the policyholder or authorised representative.
What are cookies?
Our cookie policy is part of this Privacy Policy. A cookie is a small file requesting permission to be placed on your computer’s hard drive. Cookies help analyse web traffic, track site visits, and personalize web applications based on your preferences.
We use traffic log cookies to identify page usage, aiding data analysis to improve our website. This data is used for statistical purposes and then removed. Cookies enhance your website experience by monitoring useful pages without accessing your computer or unshared data. You can accept or decline cookies via browser settings, though declining may limit website functionality.
Learn more at www.allaboutcookies.org. For cookie-related questions, email dataprotectionenquiries@wpsadvisory.com.
Where we collect your information
We collect personal data directly from you or various sources, including:
- Your employer or pension scheme trustee, if you are a member of an employer’s pension scheme.
- for WPS LifeStage Money App users, if your employer provides access as an employee benefit, data from your employer (e.g., contact details, survey responses) to tailor services, processed per UK GDPR and ISO 27701.
- registration with us, questionnaires, fact finds, or product/service applications.
- phone or video calls (voice recorded), emails, letters, or meetings with our advisers.
- visits to our online client page for your company pension scheme.
- other investments with discretionary fund managers or insurance companies, with your permission.
- public or commercial sources (e.g., business directories) to verify or enhance data (e.g., address, contact details).
Why we collect and how we use your information
We take your privacy seriously and we will only ever collect and use in a transparent manner information which is personal to you where it is necessary, fair and lawful to do so for the completion of our services, as well as limiting access to your personal data to those needing to carry out the processing.
We will collect and use your information only where one of the following lawful processing conditions set out under the Data Protection laws is satisfied:
- Providing requested products or services (e.g., pension or savings products requiring name, address, date of birth, bank details).
- meeting legal or regulatory obligations (e.g., annual reviews, fraud prevention, terms updates).
- our legitimate interests (e.g., delivering information to help you achieve optimal outcomes, understanding your objectives).
- third-party legitimate interests (e.g., sharing with your employer’s pension scheme administrator for governance).
- your consent to send information about our products, services, or selected third parties.
If you do not permit data collection, we may be unable to provide requested products or services.
Third parties with whom we may share your information
When you access third-party services through our App, such as QuoteZone (insurance quotations) and PayLow (utility switching), these third parties may use their own data processors, analytics tools, and technology partners (sub-processors) to deliver their services. For example, third parties may use analytics providers like Heap to collect usage data on their platforms.
We do not control these third-party sub-processors or their data practices. When you use third-party services, their privacy policies govern any data you provide directly to them, including how they share that data with their own sub-processors. We recommend reviewing the privacy policies of these third-party services when accessing them through our App.
We carefully select our direct third-party providers in line with our ISO requirements. We may introduce additional third-party integrations in the future, which will be subject to the same principles outlined in this Privacy Policy. Any significant changes to our third-party relationships that affect your data will be communicated through updates to this Privacy Policy.
Push Notifications
We do not currently send push notifications through the WPS LifeStage Money App. By using the App, you consent to receive future push notifications, including non-marketing (e.g., service updates, subscription reminders, security alerts) and marketing notifications (e.g., product offers). You can manage or disable these notifications at any time in the App or your device settings.
Where your information is processed
The data you provide to us is primarily held in the UK and may also be held within the EEA or in countries with the same or equivalent levels of data protection, including in the US with organisations certified under the Data Protection Framework. If you have any questions or concerns about your data held with us you can write to the Data Protection Officer at the address above.
How we protect your information
We prioritise information and system security, complying with data protection obligations. All personal data, whether on paper, online, or other media, is safeguarded. Methods for handling data are documented, with procedures and audits ensuring compliance. Independent assurance and benchmarking by third-party consultants verify our security controls.
Employees are supervised, contractually obligated to protect sensitive data, and trained annually on GDPR and security. Our controls align with industry standards, managing risks to data confidentiality, integrity, and availability. Our controls also fall in line with our ISO requirements.
How long we keep your information
We will keep your personal data where you have made contact with us. If you have engaged with us and sought our guidance and advice then in most circumstances we will not delete your data. We keep your information only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.
In certain circumstances, if you do not make any contact with us, we will anonymise your records after a set period of time.
Your individual rights
Under Data Protection laws, your rights include:
- Right to be informed: Clear information about your data, its use, and sharing, as provided in this Privacy Policy.
- Right of access: Request a copy of your data via a data subject access request, provided in a machine-readable format.
- Right to rectification: Correct inaccurate or incomplete data, verified as part of our practices.
- Right to erasure: Request data deletion if no compelling reason exists for retention.
- Right to restrict processing: Request suppression of data processing in specific circumstances.
- Right to data portability: Obtain your data for use across services (e.g., with another adviser).
- Right to object: Object to data processing for our legitimate interests, though this may limit our ability to provide advice. We may continue processing for compelling grounds or legal claims.
- Rights related to automated decision-making: We do not use automated decision-making or profiling.
Contact the Data Protection Officer to exercise these rights. Most requests are free, with a one-month response time.
Force Majeure
We always want to deliver the service you are paying us to provide. However, there may be exceptional circumstances which mean this is not possible for reasons that are outside our control. Wherever possible we will give you advance notice if as a result we have to change the service we are able to provide. We will always seek to return to providing you with the service as soon as possible.
We will only do this due to occurrences that are not caused as a result of our fault or negligence and which we are unable to control, prevent or provide against through the exercise of reasonable care and diligence. These occurrences will include but will not be limited to war, civil war, act of God, fires, flood, epidemic, utility disruption, subsidence, strikes, lock-outs, insurrection or riots, embargoes, unavailability of raw materials or services, delays in transportation, changes to requirements or regulations of any governmental authority or regulatory authority.
How to make a complaint
If you believe we have not handled your data per this Privacy Policy, contact:
The Data Protection Officer
WPS Advisory Limited
Suite A, 5th Floor, West One, Newcastle upon Tyne, NE1 3PA
Email: complaints@wpsadvisory.com
We will address your concerns. You may also complain to the Information Commissioner’s Office:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
https://ico.org.uk/make-a-complaint
View our Privacy Notice at https://lifestageadvice.com/privacy/ .
