Privacy and your personal data
It applies to information collected by us or provided by you to our website (including the mobile-optimised version of the website accessible from your portable hand-held device) or in any other way (such as over the telephone). It is also intended to assist you in making informed decisions when using our website and our services.
We would like to send you information about our products and services and those of other companies in our group which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.
Information about connected individuals
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 will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
What information do we collect on our website?
When you visit our website, you may provide us with personal information such as name, postcode, email address, landline phone number, mobile phone number, and information about your requirements and the services you might be interested in (“information”).
We may collect Information about your computer, including where available your IP address, operating system, browser type and the geographical location of your computer, for system administration purposes. We may also report aggregate information to our advertisers. This is statistical data about browsing actions and patterns and does not identify you as an individual.
You voluntarily choose to provide personal details to us via this website. Personal information will be treated as confidential by us and held in accordance with the Data Protection Act 2018. You agree that such personal information may be used to provide you with details of services and products in writing, by email or by telephone.
How we use your information
We will hold, use, and disclose your Information for our legitimate business purposes including:
- To keep you up to date about important changes to our business.
- To direct-market products and services (including push notifications), advise you of news and industry updates, events and promotions, and other information. Before we do so, you will be given an option to opt-out of such communications, and an option to unsubscribe will also be provided with each communication;
- To apply profiling technology which analyses our clients’ engagement with our direct marketing communications, activity and interests so that we can send you content that is relevant to you;
- To answer your queries and provide further information;
- To release Information to regulatory or law enforcement agencies, if we are required or permitted to do so.
We may process certain sensitive personal data (known as special category data in GDPR) where you include it in information you send to us, for example, if you include information about your financial status.
We have processes in place to limit our use and disclosure of such sensitive data other than where permitted by law.
How we share your information
In certain circumstances, we will share your Information with other parties. Details of those parties are set out below along with the reasons for sharing it.
- Trusted third parties in order to provide certain services. We will share your information with third-party service providers such as printing and courier companies and technology providers. We will not share your data with any third party where it is not necessary to do so to provide a service to you.
- Regulatory and law enforcement agencies. As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
- New business owners if we or our business merges with or is acquired by another business or company. We will share your personal information with the new owners of the business or company and their advisers. If this happens, you will be sent notice of such event.
Where third parties are involved in processing your data we will 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 will only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit. This includes password protecting attachments to emails where there is confidential or sinsitive information.
How long we hold your information.
During the course of our relationship with you we will retain personal data which is necessary to provide services to you. We willl take all reasonable steps to keep your personal data up-to-date throughout our relationship.
We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, typically:
- Five years for investment business
- Three years for mortgage business
- Indefinitely for pension transfers and opt-out business
- Three years for insurance business
These are minimum periods for which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it is in our legitimate interests to do so. Subject to aforementioned, typically, we will not keep your personal data for longer than 10 years after our relationship with you has ended.
Your rights relating to your information.
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
- Right of Access. You have the right at any time to ask us for a copy of the information about you that we hold, and to confirm the nature of the information and how it is used. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
- Right of Correction or Completion. If information we hold about you is not accurate or is out of date or incomplete and requires amendment or correction, you have a right to have the data rectified, updated or completed. You can let us know by contacting us at the address or email address set out above.
- Right to be forgotten. In certain circumstances, you have the right to request that information we hold about you is permanently deleted, for example, if the information is no longer necessary for the purposes for which it was collected or processed, or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
- Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your information by contacting us at the address or email address set out above. For example, if we are processing your Information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your Information for direct marketing purposes. You may also have the right to restrict our use of your Information, such as in circumstances where you have challenged the accuracy of the Information and during the period where we are verifying its accuracy.
- Right of Data Portability. In certain instances, you have a right to receive any information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third-party organisation.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation's systems. We are also unable to comply with requests that relate to Information of others without their consent.
You can exercise any of the above rights by contacting us at the address or email address set out above; and we will make no charge. Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
To the extent that we are processing your information based on your consent, you have the right to withdraw your consent at any time. You can do this by unsubscribing via the link provided in any direct marketing communication or contacting us at the address or email address set out above.
Like other commercial websites, our website uses a technology called “cookies” and web server logs to collect information about how our website is used. A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies.
Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our website, and the websites visited just before and just after our website.
Cookies do not allow us to gather any personal information about you, and we do not generally store any personal Information that you provided to us in your cookies.
We use ‘Session’ Cookies which enable you to carry information across pages of the website and avoid having to re-enter information. Session cookies enable us to compile statistics that help us to understand how the website is being used and to improve its structure.
We also use ‘Persistent’ Cookies which remain in the cookies file of your browser for longer and help us to recognise you as a unique visitor to the website, tailoring the content of certain areas of the website to offer you content that match your preferred interests.
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.
If you are unhappy about our use of your Information, you can contact us at the address or email address above.
You are also entitled to lodge a complaint with the UK Information Commissioner's Office using any of the below contact methods:
Telephone: 0303 123 11113
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF