This privacy notice explains how we use any personal information we collect about you.
We collect information about you when you engage us for financial planning/financial advice. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations. Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
We collect information about you in order to provide you with the services for which you engage us.
In order to deliver our services to you effectively we may send your details to third parties, with your authority such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit. This may include password protection and/or encryption of data.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
We won’t share your information for marketing purposes with companies outside of our Group..
During the course of our relationship with you we will retain personal data which is necessary to provide services to you or for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We will take all reasonable steps to keep your personal data up to date throughout our relationship. Once our relationship with you has ended, we will only keep your personal data for a period of time that is appropriate for the type of personal data, and what we hold it for.
We are also subject to regulatory requirements to retain your data for specified minimum periods. We reserve the right to retain data for longer where we believe it is in our legitimate interests, or we have a legal obligation to do so.
Generally we will not keep your personal data for longer than ten years after our relationship with you has ended or your death, with the exception of occupational pension transfer, opt out and Free Standing Additional Voluntary Contributions (FSAVC) advice which must be retained indefinitely in accordance with the Financial Conduct Authority’s record keeping rules.
In some circumstances you have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
Cheshire SK9 5AF
0303 123 1113 (local rate)
By email at firstname.lastname@example.org
Or write to us at Walsingham House, 35 Seething Lane, London, EC3N 4AH
We have provided you with a copy of our Privacy Notice which provides information about the nature of our personal data processing activities and includes details of our retention and deletion policies as well as your rights of access to the personal information that we hold on you.
As explained in our Privacy Notice there are certain categories of personal data that are sensitive by nature. These categories include: data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and data concerning health.
Depending on the nature of the products and services that you engage us for we may need to obtain your sensitive personal data particularly in relation to health. In the case where we need to process special category (sensitive) data as described above we will inform you at the time and seek your consent via our servicing agreement.