Privacy Policy

This Privacy Policy explains how Pearl Lemon Limited (trading as Highwater) ("Highwater," "we," "us," or "our") collects, uses, and shares information when you visit our website (the "Site"), submit a form, book an introduction call, respond to one of our advertising campaigns, or otherwise contact us.

1. Information we collect

Information you provide

If you are a financial advice firm enquiring about our service, we may collect your name, firm name, email address, phone number, region, your firm's FCA authorisation details, and any information you choose to share about your firm or enquiry.

If you respond to one of our advertising campaigns, our qualification process may collect your name, contact details, age band, an indication of your investable assets or pension savings, your reason for seeking advice, and your preferred timing. You provide this information voluntarily so that a suitable appointment can be arranged for you.

Information collected automatically

When you visit the Site, we and the third-party tools described below may automatically collect technical information such as your IP address, browser and device type, pages viewed, referring URL, and date and time of access, including through cookies and similar technologies.

Information from third parties

We may receive information from the advertising platforms and service providers that power our campaigns, forms, and scheduling, for example when you respond to an advertisement, submit a form, or book a call.

2. How we use information

• To respond to enquiries from financial advice firms and to schedule and conduct introduction calls;
• To run and qualify advertising campaigns, and to arrange and deliver appointments on behalf of the firms we work with;
• To provide, operate, maintain, and improve our services and the Site;
• To send information you request and, where permitted, relevant follow-up about our services;
• To maintain security, prevent fraud or abuse, and comply with legal and regulatory obligations.

3. How we use information in advertising campaigns

Highwater runs paid advertising aimed at UK adults aged 50 to 65 who hold £250,000 or more in investable assets or pension savings. Every promotion is prepared in accordance with FCA financial promotion rules and Consumer Duty standards, and runs under the Highwater brand.

Where you respond to a campaign and pass our qualification process, the information you provide is shared with a single client firm so that the firm can prepare for and hold your appointment. We do not share your details with more than one firm, and we do not sell your information.

4. How we share information

We do not sell your personal information. We share it only with:

• Client firms. Where you respond to a campaign and are qualified for an appointment, your details are provided to the one FCA-authorised firm with which your appointment is booked.
• Service providers that process data on our behalf, including advertising platforms (such as Meta), our scheduling and form tools, our customer relationship management system, our website hosting provider, and font delivery. Each handles data under its own privacy terms.
• Legal and safety reasons, when required by law, or to protect the rights, safety, or property of Highwater or others.
• Business transfers, in connection with a merger, acquisition, financing, or sale of assets.

5. Cookies and similar technologies

The Site and the embedded tools above use cookies and similar technologies to make the Site work, remember preferences, understand usage, and measure the performance of our advertising. You can control cookies through your browser settings; disabling some cookies may affect how parts of the Site function.

6. Data retention

We keep personal information for as long as needed to respond to you, provide our services, arrange and support appointments, and meet legal, accounting, or regulatory requirements, after which we delete or anonymise it.

7. Data security

We use reasonable technical and organisational measures to protect your information. However, no method of transmission over the internet or electronic storage is fully secure, and we cannot guarantee absolute security.

8. Your rights

Under the UK GDPR and the Data Protection Act 2018, you have the right to access, rectify, erase, restrict, or object to our processing of your personal data, and to data portability. Where we rely on your consent, you may withdraw it at any time. You can also opt out of marketing emails at any time using the unsubscribe link or by contacting us.

Our legal bases for processing include your consent, our legitimate interests in operating and marketing our business, the performance of a contract, and compliance with legal obligations. To exercise any right, contact us using the details below. You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority.

9. Third-party links

The Site may link to third-party websites, for example LinkedIn. We are not responsible for their content or privacy practices; please review their policies.

10. Children's privacy

The Site and our services are intended for adults and are not directed to children. We do not knowingly collect personal information from anyone under 18.

11. International transfers

We operate from the United Kingdom. Where a service provider processes data outside the UK, we rely on appropriate safeguards, such as the UK International Data Transfer Agreement or standard contractual clauses, to protect your information.

12. Changes to this policy

We may update this Policy from time to time. Changes take effect when posted, and we will update the "Last updated" date at the top of this page.

13. Contact us

Pearl Lemon Limited (trading as Highwater)
152-160 City Road, London EC1V 2NX, United Kingdom
Email: info@pearllemongroup.com