Customer Privacy Notice

This privacy notice tells you what to expect us to do with your personal information.

This Policy applies if you are in the UK or if we process your personal data.

Who we are

Controller: Pen-gage Ltd

Registered Office: Suite 112, Design Works Business Centre, William Street, Gateshead, NE10 0JP

(“we”, “us”, “our”)

We are the data controller for personal data we collect and use. This means we determine the purposes and means of processing your information.

What information/personal data we collect, use, and why

We may collect and use the following categories of personal data, depending on the service you engage with:

Identity & Contact

Names, email, telephone, postal address

Financial & Employment

Income/expenditure details, employment details, salary, pension scheme info

Service Usage

Account details, registration details, interaction records

Marketing & Communication

Preferences, consent records

Cookies and Online Identifiers

If collected via digital services (refer to our Cookie Policy)

How We Use Your Personal Data & Lawful Basis

Under UK GDPR, every processing purpose must have a lawful basis.

Purpose	Legal Basis
To provide services you request (e.g., pension planning)	Contractual Necessity
Account administration	Contractual Necessity
Customer service and support	Legitimate Interest
Marketing (email/SMS)	Consent (explicit)
Compliance with legal obligations	Legal Obligation
To protect client welfare	Legitimate Interest
Legal claims / queries	Legal Obligation / Legitimate Interest

We will only rely on Consent for marketing and any optional processing. You are free to withdraw consent at any time.

Sharing & Disclosure

We may share personal data with:

Service providers (IT, hosting, support) acting on our behalf.
Professional advisors (e.g., legal, audit).
Regulatory, law enforcement or public bodies where required by law.

If we transfer data outside the UK, we use appropriate technical and organisational safeguards (e.g. UK Standard Contractual Clauses).

Retention Periods

We retain personal data only as long as necessary for the applicable purpose, including compliance with legal or regulatory requirements. Typical retention periods include:

Client service records: up to 7 years (or as required by law)
Marketing consents/preferences: until withdrawal
Queries and complaints: as long as necessary to resolve and for legal compliance

Where a specific period is not applicable, we will explain the criteria used to determine retention. Our retention policy is available on request.

Your Legal Rights

You have the following rights:

Right of access
Right to complain
Right to rectification
Right to erasure
Right to restriction
Right to objection
Right to be informed
Right to data portability (where applicable)
Right to prevent automated decision making

Automated Decision-Making

Where applicable, we will tell you when you are subject to automated decisions, including logic and consequences.

Cookies & Online Tracking

Separate cookie and tracking technologies may collect personal data. See our Cookie Policy for details on:

What technologies are used
What data is collected
How you can manage your preferences

Changes to This Policy

We may update this Notice to reflect changes in legal requirements, processing activities, or services we provide. We will prominently display the revised “Last Updated” date.

Contact & Complaints

Questions, requests, or complaints about this Notice or our practices should be sent to: hello@pengage.co.uk.

If unresolved, you can complain to the Information Commissioner’s Office:
ICO Helpline: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Policy Review & Approval

This Policy is reviewed:

Annually
Following legal or regulatory change
Following new processing activities or systems

Last Updated

9 January 2026