What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances and may identify you directly, for example your name, address, date or birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your Retirement, Investment, Mortgages, Finance and Insurance requirements Your Personal Data may include:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, e-mail address, addresses and documents that are necessary to verify your identity
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
- Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
- Any pre-existing retirement, investment, mortgages, finance and insurance products and the terms and conditions relating to these
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example your insurance, ethical investments, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance, investment providers in relation to insurance products that may meet your needs and to provide you with advice and/or guidance regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
How do we collect Your Personal Data?
We automatically collect some data about our users’ browsing actions and traffic patterns. This is aggregate data that does not identify any individual and will list which of the Website pages are most frequently visited and by which types of users. We may also ask you to provide information on a voluntary basis in order to get a clearer picture of our users. It is then entirely up to you whether you are happy to give us this information.
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. In the course of asking us for information to provide retirement, investment, mortgages, finance and insurance quotes you will be asked to provide some details about yourself and your partner. You may also provide information during the course conversations with you or in writing to establish your circumstances and needs and preferences. You may also choose to e-mail us or make contact with us in other ways. Such contact gives us information about you.
We may collect more specific information about some of our users. This may include your name, e-mail address, marital status, the address where you live, a contact telephone number, details about you or your partners pension arrangements or details about you or your partners health and medical conditions.
We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. We use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we and our partner authorised firm will:
- Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by a partner authorised firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
- Submit Your Personal Data to Product Providers, Mortgage Lenders, Commercial Lenders and/or Insurance Product providers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investment, mortgage, finance product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.
In common with many other website operators, we may use standard technology called ‘cookies’ on this Website. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive and they are used to record how you navigate this Website on each visit.
Our cookies are used to enable us to develop our Website to reflect our customers interests and by noting who has seen which pages and advertisements, how frequently particular pages are visited and determining the most popular areas of our Website.
The Cookies We Set
This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
In order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.
Third Party Cookies
This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.
From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.
In some cases we may provide you with custom content based on what you tell us about yourself either directly or indirectly by linking a social media account. These types of cookies simply allow us to provide you with content that we feel may be of interest to you.
We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; LinkedIn, Facebook, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Retirement Providers, Investment Providers, Mortgage lenders, Finance lenders and Insurance providers.
- Third parties and partner authorised firms who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties and partner authorised firms will include but may not be limited to, our Compliance Advisers, Product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).
We may provide aggregate data about users, traffic patterns and related site information to reputable third parties but this data will include no personally identifying information.
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
Your rights in relation to Your Personal Data
Here are the options you can ask for in relation to Your Personal Data:
- request copies of Your Personal Data that is under our control
- ask us to further explain how we use Your Personal Data
- ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
- ask us to send an electronic copy of Your Personal Data to another organisation should you wish
- change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
How to make contact with us in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
Colin Thorburn by emailing at email@example.com
If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at ICO contact us or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Links to other websites
Our Website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website.
Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.