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.
We collect, control and process 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 personal details and those of your employees and service providers other than sensitive personal data for which individual consent is required. We do not normally request or process any sensitive personal data.
Sensitive 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 sensitive data before you provide this information. The subsequent provision of sensitive personal data will be taken as consent to this processing.
It is entirely up to you as to whether or not you choose to provide us with any personal information. If you choose not to, we simply may not be able to assist you.
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
Completing our initial enquiry form
What we will do with your enquiry
Once we have responded to your enquiry your data will be transferred to an encrypted server, located either in the EEA or US. If this is a US based server, this will be covered by the EU-US Privacy Shield. Where communications are ongoing we will store your contact details and use cloud services to share them across our devices to facilitate this.
Working with us
We collect and use information about you and your clients, which will include personal data in order for us to provide services to you. In order to communicate with you about our services we will require your contact details including email addresses. Your name and email and information relating to the work we undertake for you will be processed and stored.
Sharing the 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.
This will include:
- Product & service providers in relation to investments, plans and pensions.
- Our compliance services.
- The Financial Conduct Authority.
- The Financial Ombudsman Service.
- Any other regulators where so required.
We also use external Data Processors that will hold information for the following purposes:
- Secure file sharing
- Data backup
- Record keeping
- Regulatory compliance
All external processors are only permitted to process the data in line with our instructions.
Data processors privacy
Below is a list of the processors used and the types of information processed. Please note that the Privacy & Security policies of the processors are aimed at the controllers who use them and may be updated.
|Processor||Type of processing & data|
|Basecamp||We use Basecamp to securely share files and documents that contain or may contain personal data pertinent to the work we undertake for clients and for our staff.|
We use Google to securely share documents that contain or may contain minimal personal information – names and contact details – to record enquiries and monitor workflow.
We also use Google Analytics to monitor details about web searches and website interaction.
|Dropbox||We use Dropbox to securely share files and documents that contain or may contain personal data pertinent to the work we undertake for clients and for our staff.|
|SelectaPension||We use SelectaPension for research and enter personal information to conduct research and analysis.|
|Financial Express||We use Financial Express for research and enter personal information to conduct research and analysis.|
|Synaptics||We use Synaptics for research and enter personal information to conduct research and analysis.|
|Webline||We use Webline for research and enter personal information to conduct research.|
|Moneyscope||We use Moneyscope for research and enter personal information to conduct research and analysis.|
|Freethought Internet||Freethought Internet host our website and provide some email services to us.|
|Kashflow||We use Kashflow for invoicing purposes.|
In all cases we seek to minimise the amount of personal data shared. It is essential, 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.
Where we store your Personal Data
All the data that we collect and store on a cloud based server is encrypted. Such servers are located either in the EEA or US. If this is a US based server, this will be covered by the EU-US Privacy Shield. Data may also be stored with our listed processors under contract.
We also store data on computers and encrypted back-up drives located within a UK office, which has 24 security, CCTV and a controlled entry system.
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.
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 ask us to delete or cease processing all personal data held by us or any processor with which we have shared your data. We may not always be able to comply with a request for deletion, but you can ask us to cease processing your data.
In addition you have the right to be informed about the data we collect, where is located and with whom it is shared and the processing we undertake and to question any automated decision making processes
To do this, or if you require more information please either contact us in writing, by telephone or email.
We have the right to inspect any documents or data held by you as the data controller which are or could be relied upon by either party, or are pertinent to, a claim or potential claim brought by the data controller or any third party, subject to reasonable notice and such access should not be unreasonably withheld.
We are registered as a Data Controller in the UK with the Information Commissioner’s Office. However, in the even of a complaint, please contact us in the first instance.
For any queries about data protection please contact:
|Contact name||Alan Gow|
|Address||Reading Business Centre, Fountain House, 2 Queens Walk, Reading, RG1 7QF|
IP Addresses and 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, 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 do not collect information that can identify a particular visitor. These cookies are usually persistent and have fairly long expiry rates.
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.
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.