Privacy policy

1. Who we are

This policy explains how PJG Financial Limited, trading as Protection Connect (company number SC535782, registered office 5 South Charlotte Street, Edinburgh, EH2 4AN), which is authorised and regulated by the Financial Conduct Authority (FRN 919697), uses personal data through Protection Connect. We are registered with the Information Commissioner's Office under reference ZB537016. Protection Connect, LifeAdviser and 50Life are all trading styles of PJG Financial Limited. LifeAdviser and 50Life have their own privacy notices for consumers. Contact us about privacy at contact@protectionconnect.co.uk.

2. Data we collect about brokers

When you apply for or use an account we collect your name, firm name, job title, work email, phone number, your firm's FCA reference number, your FCA Individual Reference Number, your firm's ICO registration number, login and usage information, the IP address, approximate location and browser details recorded when you apply, sign in and use the platform, and records of the enquiries you buy (by hand or automatically) and the messages you send us. We also record the leads you view in Available leads, your automatic buying settings and their history, and your card authorisation for automatic buying: when it was given, by whom and for which saved card. When you pay for a lead by card, we also keep the billing details we need, such as amounts, dates and payment references. You enter your card details on Stripe’s own secure page or form, so we never see the full card number.

You can buy a lead by hand without a saved card by paying on Stripe's secure page, where the card you use is saved. Automatic buying runs only while your firm has a saved card. We don't offer account top-ups. Stripe keeps your saved card. We keep only Stripe's references for your customer record and the saved card, and when and by whom it was saved, never the card number. The card brand and last four digits shown in your dashboard come from Stripe.

We use this to verify your firm against the FCA register, run your account, provide support, prevent fraud and meet our legal and regulatory duties. We also use it to deliver the enquiries you buy, take payment for them and pay back any unused balance. We also email the buyers of firms that can buy when enquiries have been waiting for 30 minutes during working hours. We may link accounts that appear to share an owner or payment card, to share enquiries fairly between firms and prevent misuse. To do this we use a reference Stripe gives us for each card, never the card number. Our lawful bases are performance of our contract with you, our legitimate interests in running and protecting the platform, and legal obligation.

3. Applying for an account

When you apply for an account we collect your name, email address, phone number, role, firm and FRN (and principal firm if you're an appointed representative), trading name, protection qualification and optional CII PIN, your FCA Individual Reference Number (IRN) if you have one, your firm's ICO registration number, your answers about your business (expected leads per month, products, insurers, number of advisers, how you heard about us), the declarations you confirm (with their wording version), how you signed in, and your IP address and browser details at the time you apply. We use your IP address to prevent fraud and abuse.

We also record which advert or link brought you to sign up (for example the Google advert's campaign and keyword, or the website that linked to us) with your application, to measure our advertising (our legitimate interests). We don't use cookies for this.

We check the information you give us automatically against the Financial Conduct Authority's Financial Services Register while you apply, and again when you submit: your firm's status and permissions, any appointed representative relationship, its regulatory record, and whether you are listed at your firm under the IRN you give, including any disciplinary history or prohibition shown on your entry. We also compare the domain of your email address with the website on your firm's register entry, and may check Companies House. If your sign-in email isn't at your firm's website domain, we ask you to confirm a work email address there with a one-time code. We keep that address and when it was confirmed; the code is stored only in scrambled form and expires after 15 minutes. If you ask for a code but don't use it, we delete the address after 30 days, and if you confirm it but don't send your application, after 90 days. We record each result, where it came from and when it ran. We don't check your ICO registration number automatically; we keep it and may check it on the ICO's public register.

If every check passes, your application may be approved automatically. If not, a member of our team reviews it. Where the register shows your firm can't be eligible (for example it isn't authorised, or its permissions don't cover advising on protection) we tell you straight away. You can ask for a person to review any automated result (see Your rights below).

Security and activity records

When you apply, sign in and use Protection Connect, including our staff console, we record your IP address, the approximate location it points to (country and town), your browser and device details, the time, your user and firm identifiers, and what you did (the page or action, and whether it succeeded). A new sign-in is recorded the first time your session is used. We use these records to keep the platform secure, to prevent and detect fraud and misuse, and as evidence of who applied for, approved or acted on an account. We keep them for two years and then delete them. The IP address and browser details recorded when you submit your application are kept with your application (see section 10).

4. Signing in with Google

If you choose Sign in with Google, Google shares your name, email address and Google account ID with us and, if you use a Google Workspace account, your organisation's domain. We use them to create your account and to sign you in.

Google's own privacy policy explains how Google handles your data.

4A. Our help assistant

Pip, the help assistant on our website and in the broker portal, is an automated AI assistant. It answers questions about Protection Connect using only the pages on our website and the help in the broker portal, and it can't see your account, balance, leads, payments or support requests. Its answers are written automatically and can be wrong: our Terms and your dashboard are the final word.

When you ask a question, we send it to Anthropic (section 8) as you typed it, after removing email addresses, phone numbers and postcodes, together with up to three of your earlier questions and Pip's answers in the same chat, the page you were on and whether you were in the broker portal. We don't add your name, email address, IP address or account details. Anything else you type, such as a name or a health detail, is sent as typed, so please don't type a customer's details into it.

We don't keep your questions or Pip's answers. Your browser keeps the chat in this tab's session storage until you close the tab or log out (see our cookie policy). To stop misuse and control our costs, we count questions: our database keeps a one-way coded version of your IP address (for IPv6, of its first half) and of its network, each with a count, and deletes them about a day after your last question. We never store the address itself. Our records show only totals, such as the number of questions answered, with no question, answer or IP address.

We use our legitimate interest in answering questions about our service quickly and in preventing misuse of it (UK GDPR Article 6(1)(f)).

5. Lawful bases for applications and accounts

Contract: we use your application details to take the steps you ask for before entering into a contract with you, such as considering your application, and then to perform that contract by opening and running your account.

Legitimate interests: we check applications against the Financial Services Register and may check Companies House, and we keep security and activity records (IP address, approximate location, browser details and actions), because we have a legitimate interest in keeping the platform secure, preventing and detecting fraud and misuse, keeping evidence of decisions and actions on accounts, and meeting the expectations of our regulator, the FCA. We have balanced these interests against yours: the records are limited to what we need, are seen only by our staff, and are deleted after two years.

Legal obligation: we keep some records because the law requires us to.

6. Data in customer enquiries

Enquiries come from consumers who ask, on our LifeAdviser or 50Life websites, to be contacted about protection insurance. An enquiry can include name, contact details, date of birth or age, smoker status, cover amount, term and location. A joint enquiry, for a consumer and their partner, also includes the partner's age and smoker status, but never the partner's name or contact details.

On LifeAdviser and 50Life we act as an introducer: we don't give advice or arrange policies. We introduce each consumer to one firm only: one FCA authorised firm or one of its appointed representatives that buys the enquiry through Protection Connect. That firm gives any advice, arranges any cover and pays us a fee for the introduction, at no extra cost to the consumer. We don't tell the consumer which firm will contact them; the firm says who it is when it contacts them. The privacy policy on the website the consumer used explains this before they send their enquiry. Smoker status is information about health. We share smoker status, including a partner's in a joint enquiry, with the firm that receives the full enquiry, for insurance purposes (UK GDPR Article 9(2)(g) and the Data Protection Act 2018, Schedule 1, Part 2, paragraph 20), under our appropriate policy document. We may also show it in the preview described below on the same basis if we switch this on. We don't sell lists, and we never supply the full enquiry, or the consumer's name or contact details from it, to more than one firm.

Once a firm receives an enquiry, it becomes a separate controller of that data and is responsible for handling it lawfully. The full consumer privacy notice is on the website the consumer used.

If the same consumer enquires again for the same type of lead within 30 days of a firm paying for their earlier enquiry, we send the new enquiry to that firm at no charge and tell it that the consumer has enquired again, provided the firm is still approved, has a current FCA status, has accepted version thirteen or later of our broker terms, owes nothing and is not suspended or paused. The same type of lead means the same website, product and single or joint choice. In that case, we don't list the new enquiry for other firms. If the firm does not meet those conditions at that time, we may list the new enquiry for any firm to buy. The 30 days run from the earlier purchase. A free repeat enquiry does not restart that period. If the consumer's earlier enquiry was not bought, we list the new enquiry as normal and it replaces any earlier listing of the same type for that consumer still for sale. A new enquiry of a different type is listed as normal for any firm to buy, alongside any earlier listing still for sale.

Available leads

Enquiries are listed in Available leads in the broker portal so that one firm can buy each, except for repeat enquiries sent to an earlier buyer as described above. Only the signed-in users described below can see a listing, and only if their firm meets the buying conditions below or their firm is approved, has a current FCA status and is not suspended or paused but has not accepted the current version of our broker terms. In that case, they see listings without the option to buy until it is accepted. We may also show listings without the option to buy to users at firms that do not meet the other buying conditions and to team members who cannot buy if we switch this on. Listings are never shown to the public. Only a firm's owner, its admins and advisers for whom its owner has ticked "Can buy leads" on the Team tab can buy, and only if the firm is approved, has a current FCA status, has accepted version thirteen or later of our broker terms, owes nothing and is not suspended or paused. A listing shows the product, single or joint, a 10-year age band, a cover band, roughly when the enquiry was sent (less than an hour ago, earlier today, yesterday, or how many days ago), and the price. Smoker status is not shown in listings; we may show it if we switch this on (for a joint enquiry, whether neither, one or both people smoke). It never shows the website the enquiry came from, the consumer's name, phone number, email address, postcode or postcode district, exact age, their partner's other details, the term, the exact time of the enquiry, our reference or which firm bought it. After buying, the firm sees the website in the opening line in My leads. We list each enquiry only once, and we never list test enquiries or enquiries that have been withdrawn or erased or that the consumer has objected to us listing.

The first firm to buy a listing gets the enquiry: the consumer's name, contact details and the rest of the enquiry, including smoker status. It pays the listing's price, which we set, and we supply the enquiry only once payment is confirmed. A listing is for sale for up to 14 days after the consumer sends the enquiry. It stops being for sale sooner if a firm buys it, the enquiry is withdrawn or erased, or the consumer objects. After a sale, other firms whose users can see listings may still see the listing greyed out and marked as sold. We set this period between 1 and 30 days after the sale. At launch, it is 7 days. It shows the same listing details, never who bought it or the consumer's name or contact details. Users who can buy may also see the price it sold for and how long ago it sold. We stop showing the sold listing if the enquiry is erased. If no firm buys it, we don't offer it again and no firm receives the full enquiry.

The firm that buys an enquiry, when it first contacts the consumer by phone, email or text, must say that it is contacting them about the enquiry they made on LifeAdviser or 50Life and on what date, give its name, its FCA status and where to find its privacy notice, contact them only about that enquiry, and stop if the consumer asks it to. Firms must not copy or keep listings, or try to identify anyone from them.

A firm can ask us to buy matching enquiries for it automatically, up to a maximum price and a daily limit it sets. It chooses lead types and age bands. We compare a new enquiry's lead type (the website it came from, product and single or joint) and age band with firms' automatic buying settings; we never use the consumer's name or contact details for this. The website is used for matching and is never shown in the listing. Firms with automatic buying get first pick of a new listing for a short time before other firms see it. We consider matching firms in order of their maximum price, highest first. This decides only which firm receives the introduction and has no legal or similarly significant effect on the consumer.

Our lawful basis for showing listings in Available leads and matching enquiries' lead types and age bands to firms' automatic buying settings is legitimate interests (UK GDPR Article 6(1)(f)): ours in introducing the enquiries consumers send us, the consumer's in reaching a firm that can help with the cover they asked about, and firms' in finding customers. When a firm buys an enquiry, by hand or automatically, or receives a repeat enquiry as described above, we pass it on as we do any introduction: because the consumer asked us to, and on the same legitimate interests (Article 6(1)(b) and (f)). We have balanced these against the consumer's interests: a listing leaves out anything a firm could use to contact the consumer or easily identify them, only signed-in users of firms in the broker portal can see it, it is listed for a short time, and only one firm ever receives the full enquiry, including the consumer's name and contact details. Because a listing could still be linked back to the consumer, we treat it as personal data and protect it in the same way as the rest of the enquiry. The privacy policy on the website the consumer used explains this before they send their enquiry, and we only list enquiries sent under that wording. We share smoker status with the firm that receives the full enquiry for insurance purposes under the Article 9 and Data Protection Act provisions and appropriate policy document described above. We may also show it in previews on the same basis, to let firms choose enquiries they can help with, if we switch this on. Consumers can object at any time (see section 11).

7. Sharing

We give the full enquiry, including the consumer's name and contact details, only to the firm that buys it or, for a repeat enquiry within 30 days, the firm that bought the earlier enquiry (see section 6). Only the signed-in users described in section 6 can see previews, without the consumer's name or contact details and with smoker status only if we switch this on. We never show previews to the public. We also share personal data with service providers who help us run Protection Connect: hosting, database, email, card payments, checking contact details and answering questions in our help assistant. We'll name each one in section 8 before we use it. They may only use it on our instructions.

We may also share data with the FCA, the ICO, the police or other authorities where the law requires it, or with a buyer of all or part of our business. We never sell broker account data.

8. Service providers and sources

These providers process personal data for us as processors, only on our instructions:

• Supabase: our database and authentication (sign-in). Data is stored in London, UK.
• Netlify: hosting for our website and the server functions that handle applications and accounts. These functions may run outside the UK. Netlify Forms also receives the messages you send through our contact form. Netlify also tells us the approximate location (country and town) of the IP address a request comes from.
• Resend (Plus Five Five, Inc., a US company): our emails, including email confirmation, sign-in and password reset emails, and updates about your application and account. Resend stores email data in the United States.
• Stripe: card payments for leads, saved cards, refunds and the hold on a card while a lead is reserved. You enter card details on Stripe’s own secure page or form; we never see the full card number. Stripe gives us a reference for each card (never the card number), which we use to link accounts that share a card (see section 2).
• Data8 (Data8 Limited, a UK company): checks that the phone number and email address in each consumer enquiry are real and can be reached, to help make sure firms receive genuine enquiries. It receives only the phone number and email address, not the rest of the enquiry.
• Anthropic (Anthropic Ireland, Limited, part of Anthropic, the US company that makes the Claude AI models): the AI model behind Pip, our help assistant (section 4A). It receives the question you type, after we remove email addresses, phone numbers and postcodes, with up to three earlier questions and answers and the page you were on. Anthropic uses it only to write the answer, doesn't use it to train its models, and deletes it within 30 days, unless it must keep it longer to enforce its usage policy or by law.

If you use Sign in with Google, Google also receives and shares data as described in section 4.

Some of our pages, including sign-up, log-in, the broker portal and our product film, load code from unpkg.com and cdn.jsdelivr.net. When they do, your browser connects to those services, which receive your IP address and browser details.

We use the Financial Conduct Authority's Financial Services Register as a source of information about your firm when we check your application (see section 3). If you give us your IRN, we also use it as a source of information about you: your name, your roles at your firm and any disciplinary history or prohibition shown on your entry.

9. International transfers

Some service providers may process data outside the UK. Where they do, we use UK adequacy regulations or approved safeguards such as the International Data Transfer Agreement.

Anthropic processes the help assistant's questions outside the UK, including in the United States. Its data processing terms use the UK's International Data Transfer Addendum to the EU Standard Contractual Clauses.

10. How long we keep data

We keep broker account data for as long as your account is open and for up to six years after it closes, to meet legal, tax and regulatory requirements. This includes the card reference Stripe gives us and any link we make between accounts (see section 2). We also keep automatic buying settings, their history and card authorisations with broker account data.

We keep the personal details in customer enquiries, including any answers about health or smoking, for two years from the date the consumer sends the enquiry, and then delete them. We delete them sooner if the consumer asks, unless we must keep something by law.

After that we keep only an anonymous record of the transaction for accounting and regulatory purposes, such as which firm received the enquiry, the fee, and any charge, refund or credit. It contains no name, contact details, age, or answers about health or smoking, and we delete it six years after the date of the enquiry. Our accounts and audit trail keep the enquiry's reference number, but never the consumer's details.

If no firm receives an enquiry, we delete the consumer's contact details 30 days after they send it. Until then we keep them so that we can check the enquiries we receive and answer any question about them. An Available leads listing is for sale for up to 14 days after the consumer sends the enquiry. It stops being for sale sooner if a firm buys it, the enquiry is withdrawn or erased, or the consumer objects. A sold listing may still be shown as sold for the limited time described in section 6, unless the enquiry is erased.

If a consumer answers the quote questions but doesn't send their details, we delete their answers within 24 hours. We keep only the type of cover, the postcode district, whether the enquiry was for them alone or with a partner, and how they reached the website (for example from a search advert), none of it linked to them.

We keep account applications and the results of our checks for six years after the account closes. If we reject or block an application, we keep it and the results of our checks for two years.

We keep security and activity records for two years from the date they are made, then delete them. The results of automated checks and the reasons for each decision are kept with the application.

We don't keep questions asked of our help assistant. The coded counts that stop misuse are deleted about a day after the last question (section 4A). Anthropic deletes questions within 30 days (section 8).

11. Your rights

You can ask to access, correct or delete your data, restrict or object to how we use it, or receive a copy in a portable format. Some rights have legal limits. Email contact@protectionconnect.co.uk and we will respond within one month.

A consumer can object at any time to their enquiry being shown in Available leads, or ask us to delete their details, through LifeAdviser, 50Life or by emailing us at the same address. If they do while it is listed, we take the listing down as soon as we can after we receive the request, and no firm can buy it after that. If a firm already has the enquiry, we pass the request on to that firm.

If an automated check affects your application, you can ask for a person to review the result, tell us why you disagree with it and challenge it. Email us at the same address.

You can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113, though we would like the chance to resolve your concern first.

12. Cookies

We use essential cookies and similar storage to keep you signed in, secure the platform and remember your cookie choices. Our site does not set analytics or marketing cookies today. If we start to use them, we will only do so with your consent, and you can change your choices at any time. Our cookie policy has the details.

13. Changes

Version 2026-11-03-v19.

We may update this policy. The latest version will always be on this page with the date it was last updated.