Provider Terms and Conditions


The Pension App Pension Scheme 

Terms and Conditions 

This is an important document which sets out how your Pension App Pension Scheme is operated. It forms part of the contract between you and us and should be kept along with all other associated documents provided to you. 



The Pension App Pension Scheme 


The application you make for your account 


Your Pension App Pension Scheme with us which is governed by these terms. 

Available Cash 

Cleared monies held in your account adjusted for any unsettled buy and sell orders or cash allocated for pending buy orders 

Available Investment 

Any investment shown as being currently held in your account adjusted for any unsettled transactions as confirmed by us. 


The different ways that you (or any beneficiary should you die) can take money from your arrangement. 


The person(s) that will receive the benefit paid out from your arrangement. They may, or may not, also be a dependent. 

Business Day 

Any day, from Monday to Friday, excluding English public holidays. 



  • A person who was married to or in a registered civil partnership with you at the time of your death;
  • Your natural/adopted child provided he/she (i) is under the age of 18 (or 23 if in full time education) or (ii) was in the opinion of us dependent upon you at the date of your death because of mental or physical impairment; or
  • A person who falls into neither of the above categories and who at the date of your death was, in the opinion of us, (i) financially dependent on you (ii) in a financial relationship of mutual dependence with you, or (ii) dependent on you because of mental or physical impairment.

Finance Act 

The Finance Act 2004 and associated regulation as amended from time to time and any statutory re-enactment or modification of it. 

Lifetime Allowance 

The maximum amount of pension savings you can build up without having to pay additional tax charges 


An instruction received by us from Pension App to buy or sell investments within your account 

Permitted Investments 

The investments that are made available to you from time to time for investment via the Pension App 

Power of Attorney 

A document that gives an individual the authority to act for another person in legal or financial matters 

Registered Pension Scheme 

A scheme which is registered under Chapter 2 of Part 4 of the Finance Act 


Pension App Pension Scheme 

Scheme Administrator 

Quai Investment Services Limited. Quai Investment Services Limited has appointed Quai Administration Services Limited to provide administration support in connection with the scheme. However, Quai Investment Services Limited is responsible for the discharge of the functions conferred or imposed on the scheme administrator of the scheme. 

Scheme Trustee 

Quai Trustees Limited 

Serious Ill Health 

Life expectancy of less than one year 

Transfer Payments 

Any transfer in of cash or assets to your Pension App Pension Scheme from another registered pension scheme 

Transfer Out 

The transfer of your Pension App Pension Scheme to another registered pension scheme, in cash or assets. 

References to “you” shall mean the beneficial owner of the Pension App Pension Scheme. 

Reference to “we”, “us” or “our” is Quai Investment Services Limited.

Operation and Investment 

The terms of your agreement with us are set out in these Terms, each application, the Pension App Fee Guide , the scheme trust deed, scheme rules and the Pension App Pension Scheme Key Features (the scheme trust deed and rules will prevail in the event of any conflict). 

We do not provide advice about our products or allowable investments. The Pension App Pension Scheme is only available to investors on an execution only basis. If for any reason you are unsure about the suitability of the Pension App Pension Scheme for your financial circumstances, you should seek financial advice from an FCA authorised and appropriately qualified financial adviser prior to investing in a Pension App Pension Scheme. 

We will act on all instructions transmitted to us from Pension App on your behalf and we shall not be liable to you for any error that Pension App may make in the detail or provision of such instructions. 

The Pension App Pension Scheme is only available through the Pension App; accordingly all reports and documentation will be provided to you for access via the Pension App. By applying for a Pension App Pension Scheme, you agree that you do not require us to provide reports, statements, contract notes or other documentation associated with your Pension App Pension Scheme other than in electronic form via these means. You must keep your contact details up to date so that we can notify you when any important documents are sent via the Pension App. 

You accept that where we are required to provide you with written notice then this will be given to you by means of electronic correspondence as set out above. 

There may be circumstances which require us to review these Terms and Conditions and the charges being made. In this event we will write to you advising you of any amendments to these Terms and Conditions at least 30 days prior to the change taking effect. However, we do reserve the right in extreme circumstances to vary these Terms and Conditions with shorter notice e.g., a change to an existing, or implementation of a new regulatory requirement which we must action immediately. 

Value added tax will be levied on all appropriate expenses and charges at the prevailing rate. 

You authorise us to provide HMRC, the FCA and any other relevant authority with all the relevant information about your account and its investments as required by them. 

We reserve the right to sell investments if there is insufficient cash to meet the amount of any ongoing costs or charges. 

In accordance with the FCA rules we have categorised you as a Retail Client. As a Retail Client you will benefit from the greatest level of protection available under the regulatory system. 

Starting your Account 

Your account will be set up when we receive all necessary information from you or when all of our requirements have been met if this is later. We reserve the right at our absolute discretion to refuse your application without providing any reason for our decision. 

You may not open an account if you are a US Person as defined by the US Internal Revenue Service. If at any point you become a US Person as so defined, then you must inform us immediately, and we will require you to close your account. 

You may only open an account if you are UK resident over the age of 18, or you have prior agreement to transfer in an existing UK pension fund. If you cease to be a UK resident, then you must inform us immediately.

You have the right to cancel your account. The right to cancel applies on all transfers in that you instruct us to receive from other pension providers. You can find our cancellation form in the Pension App Pension Scheme Key Features Document and you have 30 calendar days from receipt of your transfer to notice to notify us that you have changed your mind and wish to cancel your transfer. We will follow any investment instructions that you have given to us during this 30-day cancellation period. If you choose to cancel your pension transfer under the terms of the cancellation rights, any investments acquired by the transferred monies will be sold and, together with any cash from the pension transfer, will be returned to the original pension provider. The amount to be repaid may be less than the amount paid to us if the value of the investment has fallen at the time it is sold. 

PLEASE NOTE: it may not always be possible to return a pension transfer payment to the original pension scheme if you cancel after the transfer has been received by us. In these circumstances you will need to arrange for another pension scheme to accept the transfer. We will retain the funds until such a time as a replacement provider has been notified to us. 


All money will be held by us as Trustee in an account designated as a trust account and segregated from our own funds in accordance with the FCA Rules. The trust account is a pooled account with one or more banks. In the event of a bank’s failure, your claim will be for a share of the cash held in all pooled accounts at the bank. The banks we use are entirely independent of us and we do not accept any liability for any default or delay in the distribution of funds in the event of their failure. 

Interest may be paid to us by banks with which we hold deposit accounts on your behalf. Currently no interest will be paid to your account. In the event that interest becomes payable on your account, the rates of interest will be disclosed to you and we will (and you authorise us to) deduct such charges as HMRC imposes from time to time on interest payments. We will retain any differences between the interest received from the banks and the amounts paid to your account. 

Dividends or other income received will be credited to your account on the day of receipt wherever practicable but no later than 10 Business Days after receipt. Any income received in the form of cash will be credited to your account. 

Transfers In

You may transfer in cash to your account. Alternatively, if you are transferring a pension where investments are held via an investment platform service and the pension investments that are held are also available under the Pension App Pension Scheme, then you may request for those investments to be transferred in-specie. If those investments under the Pension App Pension Scheme are available with lower fund management fees you will have the option to convert those investments. 

We may decline any contribution or Transfer In entirely at our discretion. 

All Transfer In values we receive will be applied to your individually designated account. 


We will accept instructions from Pension App , on your behalf, to acquire investments for your account. This is subject to: 

I. The completion by you of additional documentation if requested by us; and 

II. The legislation applicable to registered pension schemes; and

III. All other relevant statutory provisions 

We will be entitled not to acquire an investment in accordance with your instructions if: 

I. We have not received your authorised instructions; or 

II. Insufficient cleared funds are available in relation to your account; or 

III. In our reasonable opinion, the carrying out of the instruction is impossible, unlawful or impracticable; or 

IV. We have given you notice to transfer your account to another registered pension scheme in accordance with these terms and in our reasonable opinion it is not practicable to complete the acquisition of the investment before the date on which your account must be transferred or the investment is illiquid; or 

V. In our reasonable opinion, the acquisition of such an investment may impose tax or other costs on us or liabilities which in each case we may not be able to meet from your account; or 

VI. In our opinion, acquiring any investments may require us to offer to purchase further shares pursuant to the City Code on Takeovers and Mergers or any other code or legislation, or any further assets. 

We will tell Pension App if we do not acquire an investment on your behalf. 

We will use reasonable endeavours to execute any instructions we receive in accordance with these terms and conditions from you promptly. This is not always possible, so provided that we do not act unreasonably, then we will not be liable for any loss or profit forgone between the time an investment instruction was received and when it was executed. 

We will only make available investments that are in accordance with the legislation governing the investments of registered pension schemes or any other relevant statutory provision. The permitted investments broadly comprise: 

I. Stocks and shares quoted on the UK stock exchange that has a ‘Recognised Investment Exchange’ status, including securities traded on the Alternative Investment Market (AIM) 

II. Unit trusts and investment trusts (including OEICs) 

III. Deposit accounts; and 

IV. Government and corporate bonds. 

We do not support investments in so called “esoteric” or other non-mainstream products. 

All investments other than cash are held by us in an appropriate nominee name with a third party custodian or held directly in the name of the Trustee. The Trustee is the legal owner of all cash and assets within the Scheme. The trust is arranged for the benefit of the member as specified by the Rules. All allocations of investments to your account are notional only and neither you nor any other person who may be entitled to benefit under your account will acquire any legal or beneficial interests in those investments. 

We will be entitled to dispose of any investment if in our reasonable opinion: 

I. Continued retention of such investment would be unlawful or would impose tax or other costs on us or expose us to liabilities which in each case we may not be able to meet form your account; or 

II. We need to dispose of that investment to meet any fees or charges payable from your account which we may otherwise not be able to meet from your account; or

III. That investment is no longer an allowable investment as described above; or 

IV. A disposal of the investment is required by the terms of any agreement to which we are a party. 

We will not exercise voting rights in respect of any investment unless you ask us to; however, we are not under any obligation to vote in accordance with your wishes. We will not appoint a proxy in respect of any investments in your account. 

We will not be responsible for any loss (including loss of profit) in relation to, or diminution in value of, any investment: 

I. Acquired by us at your request unless such loss or diminution results from fraud, wilful misconduct, negligence or breach of regulatory duty, or the fraud, wilful misconduct, negligence, or breach of regulatory duty of any of our employees or agents; or 

II. Not acquired by us or not disposed by us in accordance with our rights under these terms; or 

III. Disposed of by us in accordance with these terms unless such loss or diminution results from our fraud, wilful misconduct, negligence, or breach of regulatory duty of any of our employees or agents; or 

IV. Which results from any action or omission of any nature whatsoever by any investment manager or by any nominee, banker, custodian, or other person providing services to any investment manager. 

Notwithstanding our entitlement not to acquire or dispose of an investment as requested by you or to dispose of an investment without consultation, we will not be under any duty to consider, or advise on, the general or specific merits or suitability of any actual or proposed investment or disposal. 

We reserve the right to amend the types of investments and the minimum amount of any investment at any time. Where possible, however we will only reduce the range of types of investments after giving you three months’ notice. 

If tax is deducted from your investment which is reclaimable by the Trustees of a registered pension scheme, then we will reclaim this money from HMRC and credit it to your account. Such tax reclaims will be submitted to HMRC by the 31st January following the tax year in which the deduction was made. The credit will be applied to your account once it is received from HMRC. 

Fees, Charges and Expenses 

The fees and charges payable and the timing of these fees in respect of your account and the circumstances in which they may be increased are set out in the Pension App Fee Guide available via the Pension App as amended from time to time. 

We will also be entitled to charge the following costs to your account: 

I. All expenses incurred by us (including claims, losses, and liabilities) in acquiring, holding, disposing of or valuing any investment or other asset of your account; 

II. All fees, charges, disbursements, and other costs charged by any investment manager, nominee, banker, custodian, anyone else providing related services or agent appointed in relation to your account or any part of your account; 

III. All taxes, duties, or levies to which we become liable as a result of acquiring, holding, or disposing of any investment or other asset allocated to your account; and 

IV. An amount equally to any tax for which we become (or reasonably expect to become) liable in respect of your account if your account does not constitute or ceases to constitute pension business as defined in


Section 431b of the Income and Corporation Taxes Act 1988 (ICTA). 

We may reimburse ourselves in respect of liability, charges, or costs by way of making a charge to your account as we may reasonably determine which we have incurred as a result of one of the following events occurring: 

I. We become liable to pay any levies in relation to the Financial Services Compensation Scheme; or 

II. We become liable to pay any tax or levies imposed on your account or on any contribution paid by you; or 

III. We become liable to make any other payment to the UK Government or any governmental agency or self-regulatory organisation of which we are (or become) a member, to the extent directly or indirectly attributable to your account. 

The above will not apply to the extent that the relevant event is attributable, directly, or indirectly, to any fraud, negligence, wilful default, or regulatory breach on our part. 

All charges, costs, and liabilities which we are entitled to charge to your account will be paid by us from your account. If at any time the credit balance on your account is not enough to cover all such charges, costs, and liabilities in full, we may: 

I. Dispose of investments at our discretion and without liability in order to pay the amounts due; or 

II. Require you to pay us the amounts due. 

If for any reason the value of your investments is insufficient to meet any such fees, charges, expenses, tax or scheme sanction charges payable or tax refunds due, you agree to pay us on demand the amount of any such shortfall. 


We are responsible for executing any order we receive from you via Pension App . You may only place orders for permitted investments made available to you through the Pension App. 

You may only place orders via the Pension App. 

You are responsible for the accuracy of your orders. You may not be able to cancel or change an order after you have submitted it. 

You must have sufficient available cash or available investments to settle any orders that you place together with any related charges. 

We reserve the right for any reason to refuse to execute an order but we will act reasonably in so doing. There may be circumstances, including (without limitation) suspension of dealing in extreme market conditions in which we may not be able to execute an order. We will, if possible, notify you of the reason. Provided we have acted reasonably, then we will not be liable for any loss or profit foregone between the time of an order was received and when it was executed, if ever. 

We may combine your order with other customers’ orders if we reasonably believe that this will not be to your disadvantage. We may have to execute your order in tranches and provide an average price per order. 

If we receive an order via Pension App then: 

I. In the case of an order to buy a fund, arrange to pass that order on the next business day to the relevant fund manager for execution; 

II. In the case of an order to sell a fund, arrange to pass that order no later than the next business day to the relevant fund manager; 

III. In any other case, arrange to pass that order to an appropriate broker to execute on the relevant exchange. If this order cannot be completed before the exchange closes at the end of the first business day then it will be cancelled, unless you have instructed Pension App to continue to try to execute it on the following business day.

Our record of the time of receipt and execution of an order will be conclusive unless it is obvious that it is wrong. 

You must notify Pension App if you receive confirmation of an order which you did not place or which has not been completed in accordance with your instructions. 

We will send to you contract notes (via the Pension App) confirming the details of your transaction by the end of the business day in which we receive confirmation from the market of the terms under which your order has been executed, or in relation to funds, by the end of the business day after we have received it from the relevant fund manager. 

Lifetime Allowance

The lifetime allowance is the maximum amount of pension savings you can build up without incurring a tax charge. 

If the value of your total pension savings exceeds the lifetime allowance you will be liable to pay a tax charge on the amount over it. Any applicable charge will be deducted from your account before any money is paid to you. For up-to-date information on tax rates and allowances you can go to 

Payments Out 

Taking Benefits 

From Minimum Pension Age you are able to access your benefits. If you would like to take benefits when you reach the Minimum Pension Age, please contact Pension App via email or chat support. The fees and charges payable and the timing of these fees in respect of your account and the circumstances in which they may be increased are set out in the Pension App Fee Guide available via the Pension App as amended from time to time.

Transfer Out 

Any request to transfer the assets from your account to another provider must be made in writing, subject to the applicable legislation and HMRC rules. This will be done as soon as reasonably practicable and will incur the prevailing transfer out charges set out in the Pension App Fee Guide as amended from time to time. 

Your account will also be liable for the following costs, charges and liabilities associated with the transfer out: 

I. Our and other parties’ investment transactions on the sale or transfer or assets; and 

II. Nominee charges on the transfer of ownership of assets (where assets themselves are transferred in specie). 

If we agree, we may transfer assets out of your account: 

I. To another pension scheme that is a registered pension scheme within the meaning of section 153 of the Finance Act 2004 or which under that section is treated as a registered pension scheme; or 

II. In accordance with any court order. 

We will not make a transfer in accordance with these terms and the trust deed and rules unless: 

I. We have an authorised instruction from your or the appropriate person to make the transfer; and 

II. We have received all required documentation and information from you, or the appropriate person, that we in our reasonable opinion believe is necessary; and 

III. We have received all charges due to us; and 

IV. All costs chargeable to your account and all liabilities of your account (including all costs arising in relation to any transfer out) have been satisfied. 

If you wish to transfer out in cash, there must be sufficient cash in your account. If investments have to be sold to

raise the required cash this may take time. Most assets classes can be sold quickly but some investment funds are illiquid and may take some considerable time to realise. 

Where the Scheme Trustee is unable to realise the value to transfer all or any of the investments of your account or is unable to do so on what we consider to be reasonable terms, we may in our absolute discretion, defer the transfer out requested under these terms until the Scheme Trustee is able to realise the relevant investments and has received the cleared funds. 

After satisfaction of all liabilities and the transfer of all assets from your account, we will close your account and you will cease to be a Member of the scheme. 

Pension sharing order 

If we receive a pension sharing order under the Welfare Reform and Pensions Act 1999 in respect of your rights under the scheme, we must comply with it. This will reduce the value of your account. We may need to deduct a charge from your account in order to cover any costs of complying with this order. Where we do this, it will be based on the amount of time we take to make the necessary changes. 

Unauthorised Payments 

If we make any payments or transactions that are considered unauthorised under HMRC rules, a tax charge may apply. If we know the value to the tax charge, we can take it from your account. If we do not know the amount we may take an amount that we decide or may delay making a payment to you. 

We rely on information provided by you, your dependant or beneficiary to calculate the tax charge. If we are unable to take the tax charge from your account you, your dependent or beneficiary will need to reimburse us. 

We can refuse a transaction if we believe that it could lead to an unauthorised payment charge or any other tax charge. 

Serious Ill Health

Serious ill health is defined by HMRC as likely having less than a year to live. If you are suffering from serious ill health, you can take all your benefits as a single lump sum (known as a ‘serious ill health lump sum’) at any age and can be paid subject to the following conditions: 

I. A registered medical practitioner must provide us with written evidence stating that your life expectancy is less than a year before the payment is made. The completed declaration will then need to be received and accepted by us before the serious ill health lump sum can be paid. 

II. You must have some lifetime allowance available at the time of payment. 

We can withhold a payment until we have received any evidence we have requested. 

We will make payment directly to you by bank transfer, to an account held in your name that has been verified by an authorised person. We will not make benefit payments to third parties unless instructed to by someone with a valid power of attorney. 

Options on Death 

In the event of your death the Scheme Trustees retain their absolute discretion to pay any individual or individuals in the proportions that they see fit following deduction of all fees, taxes and charges due at the time of payment. Any nomination made by you will be considered but is not binding and may not be followed. 

Upon your death benefits may be paid as a lump sum as defined in the Finance Act 2004 

Personal Information

We may use your personal information, including your sensitive personal information, and store it on our systems and may otherwise process it for the administration of your account. We need to know your personal information in order to provide you with the services as set out in these terms and ensure your account is administered as efficiently as possible. This includes such information as is required to comply with all legal and regulatory requirements. You can find our Privacy statement in Appendix one. 

We will not collect personal information from you that we do not need in order to provide the services we have agreed to provide to you. 

We may pass personal information relating to you to our associates or the bank for administering your account and verifying your identity and by dealing with us you confirm that you accept and consent to this. We may also need to seek additional information from you to verify your identify. In which case we may: 

I. Delay opening your account; or 

II. Withhold from you the ability to withdraw any funds until we have successfully verified your identity. 

We may disclose personal information if it is required to do so by law or are requested to do so by the Financial Conduct Authority, or any other relevant regulatory authority. 

You can ask questions about how we have handled your personal information or raise a complaint about how we have handled your personal information, by emailing the Data Protection officer (see Appendix One). If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). For further information about the ICO and their complaints procedure visit 

Annual Reporting and Valuations

Every January, April, July and October we will provide you, via the Pension App, with a statement of the current value of your account. Where appropriate the investments allocated to your account will be valued at the close of business on 5th January 5th April 5th July and the 5th October each year. If the 5th is not a Business Day, then the valuation will be as at the last Business Day before the 5th. 

We will provide you with a Statutory Money Purchase Illustration (SMPI) each year which will include what you can expect to receive on retirement based on the current value. 

The value of your account is based on the total value of the assets, along with any cash balance, at the reporting date less the value of its liabilities. We may, from time to time, adopt such valuation rules as we in our opinion consider appropriate. 


These Terms and Conditions of business, as amended will continue to apply until the provision of the Pension App Pension Scheme is terminated. All charges or fees due up to the date of termination must be paid. Termination shall be without prejudice to the completion of transactions already initiated by, or with, us on behalf of your account. 

If we terminate or suspend your account we reserve the right to encash all investments and hold the proceeds in cash pending receipt of instructions from you to transfer your Pension App Pension Scheme to another registered pension scheme. 

Complaints and Compensation

If you wish to make a complaint in relation to the services provided by Quai Investment Services Limited, then please contact the Compliance Officer at: 

Quai Investment Services Limited
16 Tesla Court
Innovation Way
PE2 6FL 

We will immediately carry out an investigation of your complaint in line with our complaints policy and will provide a written response, communicating the outcome of the investigation to you. Details of the complaint handling process are available on request. 

If you are not happy with the response and you wish to take the matter further you can refer it, without giving up any other rights you may have, to one of the following: 

In respect to the administration of your Pension App Pension Plan: 

The Pensions Ombudsman
10 South Colonnade
Canary Wharf
E14 4PU 

Telephone: 0800 917 4487 

Email: [email protected] 


Financial Ombudsman Service
Exchange Tower
E14 9SR 

Telephone: 0800 023 4567 

Email: [email protected]  


We participate in the Financial Services Compensation Scheme (FSCS) which pays compensation for financial loss only to eligible claimants when an authorised firm is in default and will carry out an investigation to establish whether or not this is the case. The scheme provides protection if an authorised investment firm is unable to pay claims against it. The amount of compensation depends on the basis of your claim. The current maximum level of compensation for investments is £85,000 per person per firm. Compensation levels are subject to change and for up-to-date details please refer to 

If your investment underperforms or loses value because of market movements, this is not covered by the FSCS. Your capital is at risk when investing in securities. 

Further information about compensation arrangements including eligibility, rules and compensation limits is available from the Financial Services Compensation Scheme website at 


These terms shall be deemed to have been made in England and shall be governed by and construed in all respects in accordance with the laws of England. The parties agree to submit to the non-exclusive jurisdiction of the Courts of England and Wales. 

If any of the terms included in these Terms is held by any Competent Authority to be unenforceable or invalid in whole or in part, the validity of the other provisions of these Terms and the remainder of the term in question shall be affected by such invalidity. 


Pension App Ltd (Firm Reference Number 986413) is an appointed representative of Direct Wealth Management Ltd (Firm Reference Number 765903), which is authorised and regulated by the Financial Conduct Authority. Registered Office for Pension App Ltd is Riverside, Mountbatten Way, Congleton, Cheshire, England, CW12 1DY. Registered in England with number 14373601.

Quai Investment Services Limited is authorised and regulated by the Financial Conduct Authority – Firm Reference Number 922590. Registered in England No 09919243, VAT No 100101222. The Registered Office for Quai Investment Services Limited is Unit 16 Tesla Court, Innovation Way, Peterborough, PE2 6FL.




Appendix One Privacy Statement 

Quai Investment Services Limited (Quai) will be known as the Data Controller of the personal information you provide to us. The company registration number for Quai is ZB125709 and the registered address is: Unit 16 Tesla Court, Innovation Way, Peterborough, PE2 6FL. 

Quai is committed to protecting and respecting your privacy. Our Privacy Statement is to let you know:

  • How and why we collect personal information
  • What we do with it
  • When and why we share it with other organisations
  • How long we keep it for; and
  • The rights and choices you have with regards to your personal information 

Contact Us

If you have any questions about how we have handled your personal information or wish to raise a complaint about how we have handled your personal information, you can contact our Data Protection Officer at [email protected].

If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). For further information about the ICO and their complaints procedure see: 

How we collect personal information 

You, your financial adviser or your employer may give us information about you by completing application forms (paper versions or our online services) or by contacting us by phone, email or letter. 

The personal information we gather may include, but is not exclusive to: 

  • Your name
  • Address
  • Date of birth
  • National Insurance Number
  • ISA or GIA Plan number
  • Gender
  • Email address
  • Telephone number
  • Bank account details
  • Emergency Contacts
  • Medical information (in certain limited circumstances)
  • Any further information required as part of a product application 

Why we need it and what we do with it 

We use your personal information in the following ways: 

  • To provide you with any services and/or information you request from us. This also includes carrying out any obligations specified in any contracts between us.
  • To comply with our legal and regulatory obligations, co-operate with the court service, our regulators and law enforcement agencies and to prevent and detect crime.
  • If we learn of your insolvency or bankruptcy (or any insolvency proceedings), we’ll transfer your details to the Official Receiver or appointed insolvency practitioner(s).
  • To check instructions you’ve given us or to resolve disputes including to establish, exercise or defend our legal rights.
  • To confirm your identity and address, this includes using automated decisions when we carry out financial crime checks.

We will not collect personal information from you that we do not need in order to provide the services we have agreed to provide to you. 

We keep the personal information we collect from you, your employer, and other third parties, where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). 

We hold personal information securely and limit access to those who need to see it. 

The personal information we collect may be transferred to and stored at a destination outside the UK. This could be to another company within the Quai group of companies or to external service providers working on our behalf. 

Where any such processing takes place, appropriate controls, such as adoption of agreements containing the appropriate standard clauses, will be put in place to ensure that the personal information is protected in the same standard as if it were in the UK. 

How long we keep it 

In most circumstances we will retain personal information for the lifetime of a plan or product or for up to seven years after the end of the relationship with us. This is to ensure we comply with our record keeping obligations, as set out by the Financial Conduct Authority (FCA) and other regulatory and legislative requirements. 

Certain circumstances dictate that we retain some specific information for longer, i.e. pension transfer information, HMRC tax records etc. 

Our retention obligations are reviewed on a regular basis to ensure that we do not keep personal information longer than we are legally obliged to. 

When we have no ongoing legitimate business need to hold your personal information, we will either delete it or anonymise it. If we can’t do this we will securely store your personal information, only use it for a purpose we’ve already communicated to you, and isolate it from any further processing until archives are deleted.

What is your data protection rights? 

Under data protection law, you have rights including: 

  • Your right of access – you have the right to ask us for copies of your personal information.
  • Your right to rectification – you have the right to ask us to rectify personal information you thinks is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure – you have the right to ask us to erase your personal information in certain circumstances.
  • Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
  • Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
  • Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your right to access. If you make a request, we have one month to respond to you. 

If you wish to make a request, please contact us at: 

Data Protection Officer
Quai Investment Services Limited
Unit 16
Tesla Court
Innovation Way
PE2 6FL 

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at the above address. 

You can also complain to the ICO if you are unhappy with how we have used your data. 

The ICOs address:

Information Commissioners Office
Wycliffe House
Water Lane
SK9 5AF 

Helpline Number: 0303 123 1113

ICO Website: