Privacy Policy

Introduction

This notice provides you with information concerning our collection and use of personal data. If you have any queries regarding this statement, please do not hesitate to contact us.

Legal basis

We collect, control and process your personal information because this is necessary to provide you with information, answer any queries you may have and for the provision of our services to you. Contractual necessity is therefore the lawful basis for collecting, controlling and processing your personal details and those of your employees and service providers other than sensitive / special category personal data for which we require individual consent unless it is obtained for insurance underwriting purposes.

Special category personal data:

• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union membership
• Genetic data
• Biometric data
• Data concerning health
• Data concerning sex life or sexual orientation

We would discuss with you the need for the provision of such data before you provide this information. Most commonly we will ask you to provide medical information where this is relevant to your financial planning needs. The subsequent provision will be taken as consent to this processing.

We do not use your personal data for marketing purposes nor will we share your data with any other organisation for marketing purposes. 

What data we collect & what do we do with it 

Visiting our website

Our website is protected by a secure socket layer. When you visit our website your IP address will be processed by Biskit Limited & Heart Internet Limited who host our site and by Starfield Technologies LLC who provide a secure socket layer with Godaddy Operating Company LLC. 

Making an enquiry

When you contact us with an enquiry we will process your data solely to respond to that enquiry. 

Doing business with us

In order to communicate with you about our services we will require your contact details including personal email addresses. Your name and email and information relating to the work we undertake for you will be stored on our password protected devices. 

All services

We collect and use information about you, which will include personal data in order for us to advise you and make arrangements for you.

Sharing your data

In order to fulfill our obligations under any contract for services we will need to share your data with third party Data Controllers and Data Processors. 

Data Controllers

This will include

• Product & service providers in relation to investments, plans and pensions.
• Our compliance monitoring services.
• The Financial Conduct Authority.
• The Financial Ombudsman Service.
• Any other regulators where so required.
• Para-planning (investment research) services.

We also use external Data Processors that will hold information for the following purposes:

• Secure file sharing
• Data backup
• Dissemination of information

All external processors are only permitted to process your data in line with our instructions. 

 In all cases we seek to minimize the amount of personal data shared and in some cases anonomise this. It is essential, however, that we can identify you quickly and easily so information shared may be identifiable as your personal data. 

We will not share your personal information in any other circumstances than those necessary for the provision of service to you or where we are required to do so by law. 

Otherwise we will not share your personal information with other companies without your express authority except if the firm is sold or where we are required to do so by law.

Marketing

The information we collect about you is used solely for the purposes for which it was provided. We will never use your data or share it for marketing purposes.

Your rights

Under data protection law you have the right to ask us for a copy of the information we hold about you, and to have any inaccuracies corrected or removed. You may also ask us to delete all personal data held by us or any controller or processor with which we have shared your data. 

To do this, please either contact us in writing, by telephone or email.

Contact

For any queries about data protection please contact:

Where we store your Personal Data

All the data that we collect is stored on our encrypted server or back up drives in the UK or with our listed processors under contract within the UK or, where data is transferred outside the UK we ensure it is passed to an acceptable jurisdiction.

IP Addresses and Cookies

Our website uses cookies purely to enhance your experience. 

(A cookie is a piece of information that is stored on your computer's hard drive which records how you have used a website. This means that when you go back to that website, it can give you tailored options based on the information it has stored about your last visit.)

Vital cookies!

Ones that are essential to the operation of the website. These cookies enable a site to remember text entered in a page within the same session or to remember whether a user is logged in or not, the site cannot function without them.

Performance cookies

Performance cookies, which collect information about website usage to enhance the web experience. Examples of these include website analytics (i.e. Google Analytics) and ad-response rates (where data is collected exclusively for calculating click-through rates). They don’t collect information that can identify a particular visitor. These cookies are usually persistent and have fairly long expiry rates. 

Functionality cookies

These remember the choices that users make within a web page, such as usernames, language or region to provide an enhanced, more personalised web experience. They cannot track your activity on other websites and are anonymous. 

Advertising cookies

Targeting or advertising cookies collect information about your browsing habits to tailor third-party advertising to meet your interests. They are usually placed by advertisers with website operators’ permission. We do not use this type of cookie. 

Any changes we may make to our privacy policy in the future will be posted on our websites where appropriate or may be notified to you by post or e-mail.