Privacy Policy

The privacy policy explains what personal information we collect when you visit the Encore Financial Planning website or engage with our services and how we use your data.

ABOUT US

Encore financial planning is a trading style of Barras Capital Management plc. Our Data Protection Registration Number is ZB107418. Barras Capital Management plc are registered as a data controller for personal information collected through this website and through our services.

You can contact us by email at info@barrascapital.com

WHAT PERSONAL DATA WE COLLECT AND HOW WE USE IT

We collect personal data from you in the following ways:

When you contact us - by email, by phone, or by booking a call: your name, email address, phone number, and anything you choose to tell us about your situation.
When you complete the "Am I Already There?" assessment - your name, email address, and your answers to the questions in the assessment.
When you request a copy of No Is The Goal - your name and email address.
When you become a client - the additional information needed to provide regulated financial planning advice. The specifics of what we collect, why, and how it is used are explained separately in the client agreement we send before any engagement begins.
When you visit the website - basic technical information through cookies (see below).

We use your data to respond to your enquiry, to send you the materials you've asked for, to deliver our services if you become a client, and to keep the records we are required to keep as a regulated firm.

Under UK GDPR, we rely on the following lawful bases:

Legitimate interests - for responding to enquiries, sending materials you've requested, and the day-to-day running of a small advice firm. You can object to processing on this basis at any time.
Performance of a contract - once you become a client, to deliver the planning service you've engaged us for.
Legal obligation - to meet our record-keeping obligations under FCA rules (SYSC 9), HMRC requirements, and anti-money-laundering legislation.
Consent - for any marketing emails you've specifically opted in to. You can withdraw consent at any time using the unsubscribe link in any email.

This data will be securely stored and kept as long as is appropriate to handle the enquiry.

WHO WE SHARE YOUR DATA WITH

Your personal data is handled by Barras Capital Management Limited and Encore Financial Planning directly. To run the practice, we use a small number of carefully selected third-party service providers who act as data processors on our behalf:

AdviserCloud - our UK-based regulated client management system, used to maintain client records.
Microsoft 365 (including SharePoint and Outlook) - for email, document storage, and operational backup.
Wix - the platform that hosts this website and processes contact form submissions.
Tally - the platform that hosts the "Am I Already There?" assessment.
Kit (formerly ConvertKit) - the platform we use to send the No Is The Goal book and any associated emails as well as our periodic Newsletters.
Our regulatory principal, Barras Capital Management Limited - for compliance oversight as required by our regulatory permissions.

We may also share data with HMRC, the FCA, the Financial Ombudsman Service, the Financial Services Compensation Scheme, or other regulatory and legal authorities where we are required to do so by law.

We never sell your data to anyone, and we never share it for marketing purposes outside of the providers listed above.

INTERNATIONAL TRANSFERS

Some of the providers we use are headquartered in the United States. Where this is the case, we rely on the UK Extension to the EU-US Data Privacy Framework, which the UK government has determined provides an adequate level of data protection. Where a provider is not certified under the Data Privacy Framework, we rely on UK International Data Transfer Agreements, the UK Addendum to the EU Standard Contractual Clauses, or equivalent safeguards approved under UK GDPR.

HOW WE USE COOKIES

We use cookies to monitor traffic to the site in order to improve user experience. You can read more about our use of cookies below.

YOUR RIGHTS

These are the rights you have in relation to your personal data:

Right to be informed – we need to tell you various things about us and our data processing activities.
Right to access – you have a right to ask if we hold personal data about you and, if so, you have a right to access that data and to know how it’s used.
Right to rectification – you have a right to have your personal data updated if it is not correct or completed it if it’s incomplete.
Right to erasure (the “right to be forgotten”) – you have a right to have your personal data removed from our systems.
Right to restrict processing – you have a right to restrict our processing of your personal data.
Right to data portability – you have a right to be provided with a copy of your personal data in machine-readable electronic format.
Right to object – you have a right to object to processing of your personal data in certain circumstances.
Right to object to automated processing – you have a right to object to decisions based on automated processing (including profiling).

Many of the above rights contain exceptions and conditions that affect how and when they apply. You can find out more information about individual rights at the ICO website ico.org.uk.

If you want to see a copy of any personal data we hold about you, or exercise any of your other rights, please send your request by email to info@barrascapital.com.

You also have a right to lodge a formal complaint the relevant supervisory authority (the ICO) if you think we’ve breached your rights.

HOW TO CONTACT US

If you have any questions or complaints about our data privacy policy or personal data that we may hold about you please contact us by email at info@barrascapital.com.

THIRD PARTY LINKS

This privacy policy does not cover other websites that we may link to from this website.

UPDATES

Updates to our data privacy policy will be published here. This policy was reviewed and updated on 21st November 2025.

MORE ABOUT COOKIES

We use “cookies” as part of a normal business procedure. Cookies are small text files that are created by a web server and stored on your computer when you visit a website. The website that created the cookie can read the contents when you are at their website.

Many websites use cookies to improve your browsing experience e.g. remember your log-in details, record which items you have selected to purchase, or even tailor what content is displayed depending on your preferences. Cookies can also be used to record ‘analytics’ data i.e. which web pages you visit, whether or not you arrived at the web page by clicking on an advertisement or an affiliated website. Many websites find the collection of analytics data valuable in improving the quality and content of their websites.

We use cookies for the following purposes:

Google Analytics – To monitor traffic to the site in order to improve user experience.

All the major browsers allow you to block cookies and delete those that have already been created on your computer, usually within the ‘Tools’ section of the browser. These tools allow you to specify which cookies you will accept by type and often by specific websites using an exception list e.g. you can block all cookies and then list the website from which you will accept cookies.