6. Your Individual Rights
You have certain rights under applicable legislation, and in particular under Regulation EU 2016/679 (General Data Protection Regulation or ‘GDPR’). We explain these below. You can find out more about the GDPR and your rights by accessing the European Commission’s website.
Right Information and access
You have a right to be informed about the processing of your personal data (and if you did not give it to us, information as to the source) and this Privacy Policy intends to provide the information. Of course, if you have any further questions, you can contact us on the above details.
Right to rectification
You have the right to have any inaccurate personal information about you rectified and to have any incomplete personal information about you completed. You may also request that we restrict the processing of that information.
The accuracy of your information is important to us. If you do not want us to use your Personal Information in the manner set out in this Privacy Policy or need to advise us of any changes to your personal information, or would like any more information about the way in which we collect and use your personal information, please contact us at the above details.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Right to erasure (Right to be forgotten)
You have the general right to request the erasure of your personal information in the following circumstances:
- the personal information is no longer necessary for the purpose for which it was collected;
- you withdraw your consent to consent-based processing and no other legal justification for processing applies;
- you object to processing for direct marketing purposes;
- we unlawfully processed your personal information; and
- erasure is required to comply with a legal obligation that applies to us.
We will proceed to comply with an erasure request without delay unless continued retention is necessary for:
- Exercising the right of freedom of expression and information;
- Complying with a legal obligation under EU or other applicable law;
- The performance of a task carried out in the public interest;
- Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, under certain circumstances; and/or
- The establishment, exercise, or defence of legal claims.
Right to restrict processing and right to object to processing
Instead of requesting erasure, you also have the right to right to restrict the processing of your personal information where:
- you contest the accuracy of the personal information;
- processing is unlawful, but you do not want us to erase it;
- we no longer need to process your personal information, but you need us to retain your information as you need it for the establishment, exercise, or defence of legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
You also have the right to object to the processing of your personal information under certain circumstances, such as:
- where the processing is based on your consent and you withdraw that consent;
- where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms; or
- where we are processing your personal data for direct marketing purposes
Exercise of this right may impact the services we can provide and we will explain this to you if you decide to exercise it. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms, and this may allow us to continue to (wholly or partly) process your personal information.
Right to data portability
With respect to automated information which you initially provided consent for us to use, or where the processing is necessary for the performance of a contract to which you are a party (or in order to take steps at your request prior to entering into a contract), you have a right to receive the personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to send it to another person.
Right to freedom from automated decision-making
As explained above, we do not use automated decision-making, but where any automated decision-making takes place, you have the right in this case to express your point of view and to contest the decision, as well as request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.
Right to object to direct marketing (‘opting out’)
You have a choice about whether or not you wish to receive information from us.
We will not contact you for marketing purposes unless:
- you have a business relationship with us, and we rely on our legitimate interests as the lawful basis for processing (as described above)
- you have otherwise given your prior consent (such as when you download one of our guides)
You can change your marketing preferences at any time by contacting us at the above details. In each and every marketing communication, we will always provide the option for you to exercise your right to object to the processing of your personal data for marketing purposes (known as ‘opting-out’) by clicking on the ‘unsubscribe’ button on our marketing emails or choosing a similar opt-out option on any forms we use to collect your data. You may also opt-out at any time by contacting us at the below details.
Please note that any administrative or service-related communications (to offer our services or notify you of an update to this Privacy Policy or applicable terms of business, etc.) will solely be directed at our clients or business partners, and such communications generally do not offer an option to unsubscribe as they are necessary to provide the services requested. Therefore, please be aware that your ability to opt-out from receiving marketing and promotional materials does not change our right to contact you regarding your use of our website or as part of a contractual relationship we may have with you.
Right to request access
You also have a right to access the information we hold about you. You can exercise this right at any time by contacting us on the above details.
We are happy to provide you with details of your personal information that we hold or process. To protect our customers’ personal information, we follow strict storage and disclosure procedures, which means that we will require proof of identity from you prior to disclosing such information. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated
Right to withdraw consent
Where the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us on the above details. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
Raising a complaint about how we have handled your personal data
If you wish to raise a complaint about how we have handled your personal data, you can contact us as set out above and we will then investigate the matter.
Sharing your personal information
We may pass your information to our business partners, third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf or to enable us to obtain a quote for you or provide you with other related services.
These third parties may include:
- Fund managers, Insurers, Insurance Brokers, or Credit Brokers.
When we use third-party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
We also work closely with various third-party product and service providers to bring you a range of wealth management solutions. When you enquire about or invest in one or more of these products or services, the relevant third-party provider will use your details to carry out their obligations arising from any contracts you have entered into with them. These third-party providers will share your information with us which we will use in accordance with this Privacy Policy.
We may transfer your personal information to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganisation, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.