Privacy Policy

1. Introduction

Wealth Capital Group Ltd, doing business as Ashby & Vane (“Company,” “we,” “us,” or “our”), is a company registered in England and Wales under company number 15910227, with its registered office at 128 City Road, London, United Kingdom, EC1V 2NX. We operate the website located at ashbyandvane.com, together with all associated landing pages, subdomains, forms, and tools (collectively, the “Site”). This Privacy Policy describes the categories of personal information we collect, how we use and share that information, and the choices available to you. By accessing or using the Site, you acknowledge that you have read and understood this Privacy Policy. For the purposes of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, Wealth Capital Group Ltd is the data controller of the personal information described in this Policy.

2. Information We Collect

2.1 Information You Provide

We collect personal information that you voluntarily submit through the Site. The specific data points vary by form:

• Advisor qualification forms: full name, email, phone number, state of residence, years of experience, annual annuity production, average commission rate, and current marketing methods
• Partner inquiry forms: full name, email, phone number, IMO/FMO name, role or title, referring advisor name, and estimated number of advisors served
• Career applications: full name, email, phone number, CV, cover letter, and portfolio links
• Call booking forms: name, email, phone number, and scheduling preferences

2.2 Information Collected Automatically

When you visit the Site, we and our third-party service providers automatically collect certain technical and usage information:

• Browser type, operating system, screen resolution, and device identifiers
• IP address and approximate geographic location derived from it
• Pages viewed, links clicked, time spent on each page, and referring/exit URLs
• UTM campaign parameters (source, medium, campaign, content, term) and referral partner codes

2.3 Cookies and Tracking Technologies

The Site uses both essential and non-essential cookies and similar technologies:

• Essential (required for Site functionality): session cookies for authentication and form state.
• Non-essential (advertising and analytics), used only with your consent where required by law:
  • Meta Pixel (Facebook) — tracks page views, form submissions, and conversion events for ad optimization and audience building
  • Google Ads (gtag.js) — tracks conversions and builds remarketing audiences for Google advertising
  • Website analytics tools — track page views and visitor counts to help us understand Site usage

Where required by UK law, we will request your consent before setting non-essential cookies via a cookie banner on your first visit to the Site. You may withdraw consent or manage cookie preferences at any time through that banner or your browser settings. Disabling cookies may limit certain features of the Site.

3. How We Use Your Information

We use the information we collect for the following purposes:

• Processing and responding to qualification form submissions, call bookings, partner inquiries, and career applications
• Routing qualified prospects to the appropriate advisor or appointment tier
• Syncing contact records with our CRM system for scheduling, follow-up, and relationship management
• Contacting you by phone, email, or SMS/text message regarding your inquiry or application
• Measuring advertising performance and optimizing our marketing campaigns across platforms
• Attributing referral partner credit when you arrive through a partner link
• Detecting and preventing spam, fraudulent submissions, and abuse of our intake forms
• Analyzing Site traffic and usage patterns to improve content, functionality, and user experience
• Complying with applicable legal obligations and enforcing our Terms of Service

Our lawful bases for processing this information under UK GDPR are: performance of a contract or steps prior to entering a contract (where you have requested our services), our legitimate interests in operating and improving our business (including marketing, analytics, and fraud prevention), your consent (for non-essential cookies and certain marketing communications), and compliance with our legal obligations.

4. SMS/Text Message Communications

By providing your phone number through any form on the Site, you expressly consent to receive SMS/text messages from Ashby & Vane related to your inquiry, including appointment confirmations, reminders, and follow-up communications. Message frequency varies. Message and data rates may apply.

You may opt out of SMS communications at any time by replying STOP to any message or by contacting us at the email address listed below. Opting out of SMS will not affect other communications. Consent to receive SMS is not a condition of purchasing any service.

5. How We Share Your Information

We do not sell your personal information to third parties. We may disclose your information to the following categories of recipients for the business purposes described above:

• CRM and Scheduling Platform: form submissions are transmitted to our customer relationship management and scheduling platform for lead management, appointment scheduling, automated follow-up sequences, and pipeline tracking
• Advertising Platforms: conversion event data (such as form completions and page visits) is shared with Meta and Google to measure ad effectiveness and build targeted audiences. This may include hashed identifiers
• Referral Partners: if you arrive through a referral partner link, limited information (name, email, phone, and form responses) may be shared with the referring partner solely for attribution and commission purposes
• Cloud Infrastructure and Storage: data is processed and stored on secure cloud servers, with access restricted to authorized personnel
• Legal and Regulatory: we may disclose information when required by law, court order, or governmental regulation, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others

6. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, maintain business records, comply with legal obligations, resolve disputes, and enforce our agreements. Lead and CRM data is retained for as long as you remain a prospective or active client, and for a reasonable period thereafter, unless you request earlier deletion. Career application materials are retained for the duration of the hiring process and for up to twenty-four (24) months thereafter to consider you for future openings, unless you request earlier deletion.

7. Your Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights in relation to your personal information:

• Right of Access: request a copy of the personal information we hold about you
• Right to Rectification: request correction of inaccurate or incomplete personal information
• Right to Erasure: request deletion of your personal information, subject to certain legal exceptions
• Right to Restrict Processing: request that we limit how we use your personal information in certain circumstances
• Right to Data Portability: request your data in a structured, commonly used, machine-readable format
• Right to Object: object to our processing of your personal information, including for direct marketing purposes
• Right to Withdraw Consent: withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal
• Rights Related to Automated Decision-Making: request human review of, and object to, any decision based solely on automated processing that produces legal or similarly significant effects concerning you

To exercise any of these rights, contact us at contact@ashbyandvane.com. We will respond within one month, as required by UK GDPR. We may request additional information to verify your identity before processing your request.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection, at ico.org.uk, or with the data protection authority in your own country of residence if outside the UK.

California Residents (CCPA/CPRA)

If you are a California resident, you may also have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, including the right to know, correct, delete, and port your personal information, and to opt out of the sharing of personal information for cross-context behavioral advertising. We do not sell personal information as defined by the CCPA. You may designate an authorized agent to submit a request on your behalf by contacting us at the email address below.

8. Data Security

We implement appropriate technical and organizational measures designed to protect personal information from unauthorized access, use, alteration, and disclosure. These measures include encrypted data transmission (HTTPS/TLS), secure cloud hosting with access controls, and automated spam detection systems. Despite these measures, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the Information Commissioner’s Office within 72 hours of becoming aware of the breach, where required by UK GDPR, and will notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms.

10. International Data Transfers

The Site is operated from the United Kingdom. Where we engage service providers or advertising platforms based outside the UK, including in the United States, we take steps to ensure that any such transfer of personal information is subject to appropriate safeguards, such as the UK-US Data Bridge, UK International Data Transfer Agreements, or other mechanisms recognized under UK GDPR as providing an adequate level of protection.

If you are accessing the Site from outside the United Kingdom, please be aware that your information will be transferred to, stored, and processed in the United Kingdom, and potentially in other countries where our service providers operate, where data protection laws may differ from those in your country of residence.

11. Third-Party Links

The Site contains links to third-party websites and services, including YouTube, Instagram, LinkedIn, and scheduling or video hosting platforms. These third-party sites have their own privacy policies, and we are not responsible for their content or practices. We encourage you to review the privacy policy of any third-party site before providing personal information.

12. Children’s Privacy

The Site is intended for use by individuals who are at least 18 years of age. We do not knowingly collect personal information from anyone under the age of 18. If we learn that we have collected personal information from a minor, we will take prompt steps to delete that information. If you believe a minor has provided us with personal information, please contact us immediately.

13. Changes to This Policy

We may revise this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the “Effective Date” at the top of this page. Your continued use of the Site following any changes constitutes your acceptance of the revised policy. We encourage you to review this page periodically.

14. Contact Us

If you have questions about this Privacy Policy, wish to exercise your data rights, or need to report a privacy concern, please contact us: