1. Important information and who we are
Money Labs Limited trading as The Pension Lab (“TPL”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy notice provides specific information on how TPL collects and processes your personal data. It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.
TPL is the data controller and is responsible for your personal data. TPL is registered with the Information Commissioner’s Office and its registration number is ZA269047.
2. Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
3. How do we collect your personal information?
TPL collects personal information from business clients and customers in the following ways:
- information you provide directly to us through our services, dashboards and websites, on any telephone conversations, over email, through the post or through our affiliated social media pages;
- identity information and documentation you provide to us online and offline;
- from third parties who we contact directly or indirectly using information you have provided to us;
- details of transactions you carry out through our services;
- details of your usage of our website and dashboard, the resources you use, how you interact with us and information about your device (e.g. your IP address, browser, operating system, etc.) or cookie settings;
- if you engage with a provider or website that uses a TPL API (or whose API we use);
- a record of any correspondence between us including but not limited to email, live chat, post and recorded telephone conversations;
- contact made with us for any reason including any enquiries or complaints; and
- completed customer satisfaction surveys.
4. What types of information do we collect?
TPL may collect, use, store and transfer different types of personal data about you. This includes information provided from our business clients, information you provide to us and information we create when providing services to you or for other customers.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Our website is not intended for children and we do not knowingly collect data relating to children.
For more details of the personal data we process, and how this data is collected or obtained, see the table below.
| Types of data | Description | Source |
|---|---|---|
| Contact information | This includes your name, address, and other contact information, such as your email address and telephone number(s).
If you work for one of our business clients we will record your business’s name, your position in the business and the business’s address, email address and telephone number(s). |
This information is collected from you if you use our services directly or from business clients or other customers when you are a recipient of services from one of our business clients or another customer.
Alternatively, we may obtain personal details from third parties. This information is taken to confirm your identity for security purposes. |
| Contact preferences | Data recording your preference to receive communications about our services. | This information will be created when you provide contact information and preferences in the course of an interaction with TPL. |
| Policy information | Your policy information including, policy number, name of your provider, date of birth, national insurance number, gender, value of your policy, signature on letter of authority | You provide much of this information yourself when you use our services and we may obtain this information from third parties such as your pension provider. |
| Client records | Records of services that you have used. | You provide much of this information yourself when you use our services. We will also generate information in the course of providing our services. |
| Customer records | Records of services that have been received by you and all interactions with us. | Information will be provided from our clients and interactions with you and records created by us when providing the service. |
| Address and Address history | We will hold records of addresses. | Information will be provided from clients or third parties, such as an advisor. |
| Contact history, including enquiries and complaints | These are details of any enquiry, complaint or claim you have made to TPL and may include copies of correspondence and call recordings. | You will provide this information to us when you contact us to make an enquiry or complaint. We will also create records relating to this contact. This will include any information you provide including any sensitive information provided. |
| Customer satisfaction survey data | Completed customer surveys used to review and improve our services. | You provide this information if you agree to complete a survey or questionnaire about the service you received. |
| Reviews on third party websites | Reviews on third party websites used to evaluate and improve our services. | If you include personal identifiers or order details in your review, TPL will use this to identify your order to evaluate and improve our services. |
| Cookie data | A cookie is a piece of information in the form of a very small text file, which is transferred to an end user’s device when a website or internet based service/application is accessed by a user. | For details of Cookies used by TPL, please see the Cookies section below. |
5. How do we use your personal data?
TPL uses the information that we collect for a number of different purposes in order to:
- provide, monitor, administer, maintain, develop and expand our services to our clients and to improve those services;
- perform internal operations, including, for example, to prevent fraud and abuse of our services and website;
- enhance or improve customers' experience of our services via customer satisfaction surveys or reviews on third party websites;
- analyse how our clients interact with or use our websites and dashboards;
- locate the existing pensions you, a financial adviser or a provider on your behalf, request us to find, by liaising, amongst others, with your past and current employers, your financial adviser, relevant government agencies and your current and past providers, such as pension providers;
- undertake all activities and communications necessary, in such manner and with such third parties as we determine to be appropriate, for the purposes of achieving the transfer or consolidation of your existing pensions into your chosen pension;
- record and monitor outbound and inbound telephone conversations to ensure consistent service levels, prevent or detect fraud, resolve queries and complaints and for performance management and training purposes;
- send notifications to you as part of our services;
- undertake research for analytical and statistical purposes; and
- respond to regulatory, government or legal requests that are either legally binding upon us or which we consider legitimate.
TPL will only process your personal data if there is a legal basis under data protection laws and the table below identifies these (more than one lawful basis may apply in some situations). In summary, these are:
- Consent: you give consent for us to process your data for a specific purpose;
- Contract: the processing is necessary for a contract or agreement with you;
- Legal Obligation: the processing is necessary to comply with the law; or
- Legitimate Interests: the processing is necessary for legitimate interests pursued by TPL or another party.
The purposes for which TPL processes personal data and the legal bases for doing so in each case are:
| Purpose | Lawful bases of processing |
|---|---|
| Providing services to a third party recipient, such as a provider who we provide dashboard consolidation services to or facilitate policy transfers. | Legitimate Interests – we need to process your data to provide these services and fulfil our contracts with our clients. |
| Customer services – dealing with enquiries, complaints or claims relating to our services. | Contract and Legitimate Interests – we may need to process your data so we can handle and resolve any enquiry, complaint or claim raised by you or another person related to a contract and or other issue. |
| Enhancing our client and customers' experience of our services and websites. For example, we use information on your visits to our websites to evaluate and understand how different people navigate our websites and how long they spend on particular pages. | Legitimate Interests – we sometimes need to process personal data to understand how you use our services so we can enhance and improve them. |
| Customer and market research and analysis, and the development of new services. For example, we use customer satisfaction surveys and reviews left with third parties to evaluate and understand how our services are working, how they can be improved and for the purposes of developing new services. We may contact you to discuss a survey or review. | Legitimate Interests – we sometimes need to process personal data to evaluate and improve our services and to develop new service offerings. |
| Security, preventing fraud and money laundering, and taking action against fraudsters or people who commit an offence. | Legitimate Interests and Legal Obligation – we sometimes need to process personal data to protect rights, property and peoples’ safety. |
| Tax. | Legal Obligation – we need to process personal data to comply with revenue and customs regulations. |
| Complying with the law, including regulatory requirements. | Legal Obligation and Legitimate Interests – to comply with our legal obligations, including regulatory conditions relevant to our services, and health and safety legislation, we sometimes have to process personal data. |
6. Who do we share your personal data with?
TPL employees, contractors or agents may access information:
- to manage our services;
- to process, deal or respond to any enquiry, complaint or other contact you have made with us;
- to contact you regarding customer satisfaction surveys and reviews left on third party websites;
- to evaluate customer satisfaction surveys and reviews and improve service delivery; and
- for troubleshooting and maintenance purposes.
Our Clients:
We share personal data with our business clients, including financial advisors acting on your behalf or a pension provider, for the purposes of providing services to them.
Previous Employers and Policy Providers
We share personal data with your past and current employers, your financial adviser, relevant government agencies and your current and past providers, such as pension providers to:
- locate existing policies you have in place and obtain details of policy providers in order to provide our services; and
- to enable us to facilitate the transfer or consolidation of your existing pensions into your chosen pension.
Other Third Parties:
We use data processors who are third parties providing elements of services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
We may share your data with other third parties (including the police, law enforcement agencies, credit reference and fraud prevention agencies and other bodies) to protect our or another person’s rights, property, or safety, in connection with the prevention and detection of crime.
In some circumstances we are legally obliged to share information. For example, under a court order or where we cooperate with a regulator undertaking an investigation into complaints or criminal conduct. We might also share information with other regulatory bodies in order to further their, or our, objectives. In any scenario, we’ll satisfy ourselves that we have a lawful basis on which to share the information and document our decision making and satisfy ourselves we have a legal basis on which to share the information.
We may transfer your personal data to the other following third parties:
- Technology service providers – our partners who provide IT, software and website services. Our main suppliers who we may share your data with include AWS, Google, Microsoft, Origo Services and OpenAI. Please contact us if you have further questions regarding our suppliers and data sharing arrangements;
- Regulators, lawyers, courts and or other governmental agencies or law enforcement agencies. TPL may be required to disclose certain personal information because it is required to by law or for the purposes of legal proceedings.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
7. Will you be contacted for marketing purposes?
We may send commercial e-mails to individuals at our business clients or other companies with whom we want to develop or maintain a business relationship in accordance with applicable laws. Individuals at our business clients can opt out of receiving marketing emails at any time by using the contact details at the end of this notice.
TPL does not conduct any form of direct marketing targeted at our customers though we may ask you for feedback on the performance of our services via customer satisfaction surveys.
We will not share your information with any third parties for the purposes of direct marketing.
8. How do we keep your data safe?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. How long do we keep your information for?
We will hold your personal information within a secure dedicated database for as long as is necessary to provide our services to our clients or to you. Once services are completed, we will determine how long to retain the different types of information about you based on our Data Retention Policy (copies available on request) and the following requirements:
- How long the information is needed for the specific purpose or purposes it is used for;
- Legal and regulatory requirements – For example, if TPL is required to retain client and or customer records for an additional period of time in order to comply with a legal (including regulatory) requirement; and
- To maintain records in the event of any potential or actual claims.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
11. What are your legal rights?
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us on the contact details above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12. How can you exercise your legal rights?
If you wish to exercise any of your legal rights, please contact TPL on the details below.
13. How can you ask questions or raise concerns?
If you have any questions about this privacy notice or our privacy practices, please contact us on the details above.
Email address: info@thepensionlab.co.uk
Postal address: Dock, 75 Exploration Drive, Leicester, LE4 5NU
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so we ask that you contact us in the first instance on the details above.
14. Changes to this privacy notice
This privacy notice may be updated from time to time so you may wish to check it each time you submit personal information to TPL. The date of the most recent versions will appear on this page (see version control). We encourage you to check our privacy notice from time to time to ensure you understand how your data will be used and to see any minor updates. If material changes are made to the privacy notice we will provide a more prominent notice.
15. Version control
This privacy notice was last updated in: April 2025.
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