In order to provide firms with our products and services (including the Turnkey Model Portfolio Service, and our Planning Technology) Timelineapp Tech Limited and Timeline Portfolios Limited will have sight of personal data for the clients using our services. Timeline is committed to protecting and respecting your privacy.

Timelineapp Tech Limited and Timeline Portfolios Limited are the controllers and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data protection officer by sending an email to

We reserve the right to update this privacy policy from time to time.


What data do we hold

We hold personal data for Advisors, Directors and Partners at the advisory firms we work with or who have expressed an interest in the services we provide. We will also hold data relating to third parties that we currently have or previously have had commercial relationships with. This data will include names, addresses, telephone numbers, email address and general correspondence received via electronic and paper form.

Whilst our client is the financial adviser, we may receive data relating to the end investor. This may include names and investment details such as portfolio numbers, balances, transaction histories.

We also hold data relating to staff members including names, dates-of-birth, addresses, National Insurance Numbers, identification, bank details and general correspondence.

We may collect information such as language, unique device identifier, IP address, geo-location, and the time zone where our website is used so that we can better understand usage habits and improve our products, services, and advertising. This information will always be used in an aggregated form and be used to help us provide more useful information to our users and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non-personal information.

If for any reason we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined and as such be applicable to the terms describing our handling of personal information


Where does the data come from

When an adviser registers on our website, they will be asked to provide personal data relating to themselves and their firm. Data may also be received via email, telephone and post.

We may be provided with data by third parties where there is a genuine need for the information.

We may collect its own data directly from websites and registers such as the FCA register.


Who we share data with

We may pass your information to third party service providers, agents and other associated organisations for the purpose of completing tasks and providing services to you on our behalf. Only personal information that is necessary to deliver the service will be shared and we will have a contract in place that requires them to keep your information secure and not use it for their own direct marketing purposes.

We will not release your information to third parties beyond the firm for them to use for their own direct marketing purposes, unless you have requested us to do so, or where we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crimes.

We will not sell or rent your information to third parties.

We will not share your information with third parties for marketing purposes.


How do we use the data

The data is used for future communications and to ensure we can provide its services to the data subject and for MI purposes, account management and adherence to the terms specified within our agreements.

We may use your data to:

  • Act as the basis for any service we provide.
  • To carry out our obligations arising from any contract entered by you and us.
  • Provide information to platforms for the purpose of arranging investment solutions.
  • Provide ongoing services to you.
  • Meet the regulatory obligations of the services we provide.

Our website may collect and use your personal information in order to operate and improve the services it provides. These uses include making the website or service easier to use by eliminating the need for you to repeatedly enter the same information and performing research and analysis aimed at improving our products, services and technologies.

Data will not be transferred outside of the European Economic Area (EEA).


How is data stored and how is this protected?

Data is stored on cloud servers. All paper records are scanned and stored on our internal systems. The paper records are then destroyed.

Data sourced from Morningstar API. Careful consideration has been taken to ensure that the information is correct but it neither warrants, represents nor guarantees the contents of the information, nor does it accept any responsibility for errors, inaccuracies, omissions or any inconsistencies herein.

All the user data is stored in our own database and isn't shared outside the company. All the users credentials are encrypted.

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.


Change of details

If any of the information that you have provided to us changes, please let us know the correct details by emailing or telephoning your usual contact at the firm as it is important that the personal data we hold about you is accurate and current


Cookie Policy (PECR, UK GDPR and DPA 2018)

  • 1.1. Our website and the functionality of our online information, trading and reporting platform available through our website (and any related sub-domains), which – if you are our client – enables you to access and manage the investments for and on behalf of the investors (TimeLine APP) use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website or access the TimeLine App and also allows us to improve those. You can find out more about cookies and how to control them in the information below.

  • 1.2. A cookie is a small piece of data (file of letters and numbers) that a website asks a visiting user to store on their device in order to remember information about them. Cookies contain information that is transferred to your computer's hard drive. Those cookies are set by us and called first-party cookies. We also use one type of third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our analytical and performance efforts.

  • 1.3. We use the following types of cookies:

    • 1.3.1. Strictly necessary cookies. These are cookies that are required for the TimeLine App to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as logging into secure areas of the TimeLine App. You can set your browser to block or alert you about these cookies, but some parts of the TimeLine App will not then work. These cookies do not store any personally identifiable information. They include cookies that enable you to log into secure areas of our website.

    • 1.3.2. Analytical or performance cookies. These allow us to recognise and count the number of visitors and traffic sources and to see how visitors move around our website when they are using it. This helps us to measure and improve the way our website works, for example, by ensuring that users are finding what they are looking for easily, and to know which pages are the most and least popular. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our website, and will not be able to monitor its performance.

    • 1.3.3. Functionality cookies. These are used to recognise you when you return to our website. This enables us to provide enhanced functionality and to personalise our content for you, greet you by name and remember your preferences (for example, your choice of region or cookie settings). If you do not allow these cookies then some or all of these services may not function properly.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name

Type & Purpose

More Information

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These third-party cookies written by Google Universal Analytics allow us to collect analytics information about your visit and to estimate our audience size and usage pattern.

Cookie usage 

Remarketing audiences

Cookie banner’ cookie

This cookie is used to remember your privacy preferences

Cookie written by our website


  • 1.4. We do not share the information collected by the cookies with any third parties.

  • 1.5. If you do not accept the use of these cookies, please disable them by clicking on the cookie settings links from our cookie banner. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our website or the TimeLine App.

  • 1.6. Except for strictly necessary cookies, all cookies will expire after at the end of each session.