Privacy Policy
This Privacy Policy applies to the “Zugo Direct” mobile application (“the App”) and the XYZ Advisors website. Zugo Direct is a trading name of XYZ Advisors Limited (“we”, “our”, or “us”), and is not a separate legal entity. We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use and protect personal data when you use the App, visit our website, or contact us.
XYZ Advisors Limited is authorised and regulated by the Financial Conduct Authority (FCA Firm Reference Number: 1008954).
1. Who we are
App name: Zugo Direct Developer / Legal entity: XYZ Advisors Limited Trading name: Zugo Direct is a trading name of XYZ Advisors Limited
XYZ Advisors Limited is the data controller responsible for your personal data, including data collected through the Zugo Direct app.
Registered address: 20 Market Hill Southam, Warwickshire, CV47 0HF
Email: nicholas@xyzadvisors.co.uk
2. Information we collect
We may collect and process the following types of personal data:
Information you provide to us This may include: • Name • Email address • Telephone number • Information you provide in messages, enquiry forms, or within the App
Technical data When you use our website or the App we may collect certain technical information, including: • IP address • Browser type • Device information • App and website usage data
This information may be collected using analytics tools such as Google Analytics.
Cookies Our website uses cookies and similar technologies to improve website functionality and analyse how visitors use the site. Further information can be found in our Cookie Policy.
3. How we collect your information
We may collect personal information through:
• Website contact forms
• The Zugo Direct app
• Email communications you send to us
• Website and app analytics tools
• Cookies used on our website
4. How we use your information
We use personal data for the following purposes:
• To respond to enquiries submitted through our website or the App
• To provide and operate the Zugo Direct app and its features
• To communicate with you regarding our services
• To operate and maintain our website and App
• To improve website and App functionality and user experience
• To comply with legal and regulatory obligations
We will not sell or rent your personal data to third parties.
5. Lawful basis for processing
Under UK data protection law we must have a lawful basis for processing personal data.
We rely on the following lawful bases:
Consent
Where you provide consent, for example by submitting a website enquiry form or registering within the App.
Legitimate interests
Where processing is necessary for our legitimate business interests, such as operating and improving our website and App.
Legal or regulatory obligations
Where processing is required to comply with legal or regulatory requirements.
6. Sharing your information
We may share personal data with trusted third parties where necessary, including:
• Website and app hosting providers
• IT service providers
• Analytics providers such as Google Analytics
These providers are required to process personal data in accordance with data protection law.
We may also disclose personal data if required to do so by law or regulatory authority.
7. International data transfers
Some of our service providers may process data outside the United Kingdom.
Where this occurs we ensure appropriate safeguards are in place to protect personal data in accordance with UK data protection law.
8. Data retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.
9. Your data protection rights
Under UK data protection law you have a number of rights in relation to your personal data.
These include the right to:
• Request access to your personal data
• Request correction of inaccurate data
• Request deletion of your personal data
• Request restriction of processing
• Object to processing
• Request transfer of your personal data to another organisation
To exercise any of these rights please contact us using the details below.
10. Cookies
Our website uses cookies to help improve website functionality and understand how visitors use the site.
You can control or disable cookies through your browser settings.
Further information about cookies can be found in our Cookie Policy.
11. Data security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration.
12. Complaints
If you have any concerns about how your personal data is handled, please contact us.
You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).
Website: https://ico.org.uk
If your complaint relates to our service or advice rather than your data, you may instead refer it to the Financial Ombudsman Service (FOS).
13. Contact us
If you have any questions about this Privacy Policy, or how we process your personal data through the Zugo Direct app or website, please contact
XYZ Advisors Limited (trading as Zugo Direct)
Email: nicholas@xyzadvisors.co.uk
14. Changes to this policy
We may update this Privacy Policy from time to time. Any updates will be published on this page and, where applicable, within the App.
Last updated: 30 July 2026