Privacy Notice

1. Who we are

39 Financials is the trading name of Mr Harvee James Patterson-Flack, operating as a sole trader in the United Kingdom.

For UK data protection purposes, Mr Harvee James Patterson-Flack is the controller of personal information processed by 39 Financials, except where we are acting solely on the instructions of another organisation as a processor.

2. Information we may collect

Depending on how you interact with 39 Financials, we may collect and process information including:

• your name and contact details;
• your business name, role and professional contact details;
• information you provide through our contact form, email or other communications;
• information needed to discuss, arrange or deliver services;
• project records, correspondence and client communications;
• billing, transaction and payment information;
• information contained within business systems or documents where access is required to provide an agreed service;
• technical information generated when you use this website, including device, browser, IP address and website usage information where collected by our website platform or analytics tools;
• information supplied by another person or organisation where it is appropriate and lawful for us to receive it.

Please do not send sensitive personal information through the website contact form unless it is genuinely required and has been agreed with us.

3. How we use personal information

We may use personal information to:

• respond to enquiries and discuss potential work;
• understand business problems, requirements and proposed projects;
• prepare proposals, scopes and engagement arrangements;
• provide, manage and improve our services;
• communicate with clients, prospective clients, suppliers and professional contacts;
• provide Xero, software, systems, process, AI, automation and operational support where agreed;
• maintain appropriate business and administrative records;
• issue invoices and manage payments;
• protect the security of our website, systems and information;
• improve our website, services and internal processes;
• comply with legal, regulatory, tax, insurance or professional obligations;
• send appropriate business communications or marketing where permitted by law.

4. Lawful bases

We only process personal information where we have an appropriate lawful basis under UK data protection law.

Contract

We may process information where this is necessary to take steps at your request before entering into a contract, or to deliver an agreed service.

Legitimate interests

We may process information where reasonably necessary to operate and develop 39 Financials, manage client and business relationships, respond to enquiries, protect our systems and communicate with relevant business contacts, provided those interests are not overridden by your rights.

Legal obligation

We may process or retain information where required to comply with legal, tax, regulatory or other statutory obligations.

Consent

Where consent is the appropriate lawful basis, including certain marketing activities or non-essential cookies, you may withdraw that consent at any time.

5. Where information comes from

Most personal information is provided directly by you, for example when you contact us, complete a website form, email us or become a client.

We may also receive relevant information from:

• the business you work for;
• accountancy practices or professional advisers;
• software platforms and business systems;
• suppliers or service providers;
• publicly available professional or business sources;
• other parties legitimately involved in a project or engagement.

6. Who we may share information with

We do not sell personal information.

Where reasonably necessary, information may be shared with or processed by:

• Squarespace and website-related service providers;
• Microsoft 365 and other communication, storage and productivity providers;
• Xero and other software platforms used in connection with agreed work;
• banking, payment and invoicing providers;
• insurers and professional advisers;
• subcontractors or other professionals legitimately involved in an engagement;
• accountancy practices where we are providing authorised subcontract or support work;
• government, regulatory, law-enforcement or tax authorities where disclosure is legally required.

We aim to disclose only the information reasonably required for the relevant purpose.

7. International transfers

Some technology providers used by 39 Financials may process or store information outside the United Kingdom.

Where personal information is transferred internationally, we expect the relevant provider or arrangement to use an appropriate UK-recognised mechanism or other lawful safeguard for that transfer.

8. How long we keep information

Personal information is kept only for as long as reasonably necessary for the purpose for which it was collected and to meet relevant legal, contractual, tax, insurance and professional requirements.

Information relating to an enquiry that does not become an engagement will be reviewed and deleted when it is no longer reasonably useful.

Client, contractual, project and financial records may need to be retained for several years after an engagement ends.

9. Security

We take reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

No internet transmission, cloud platform or electronic storage system can be guaranteed to be completely secure.

10. Your rights

Depending on the circumstances, UK data protection law may give you rights including:

• access to personal information held about you;
• correction of inaccurate or incomplete information;
• deletion of information in certain circumstances;
• restriction of processing in certain circumstances;
• objection to certain types of processing;
• data portability where applicable;
• withdrawal of consent where processing relies on consent.

To make a request, email harvee@39financials.com .

11. Complaints

If you are concerned about how your personal information has been handled, please contact us first so that we can try to resolve the issue.

You also have the right to raise a concern with the Information Commissioner's Office, the UK's data protection regulator.

12. Changes to this notice

This Privacy Notice may be updated as our services, technology, suppliers or legal obligations change.

The latest version will be published on this website.

Last updated: 1 October 2026