1.1We are committed to safeguarding the privacy of our website visitors and service users. This policy is designed to ensure that we safely handle your personal data in accordance with relevant regulations and legislation such as Data Protection Act 1998 and EU General Data Protection Regulations 2018 (the "Data Protection Regulations").
1.2This policy applies in those cases where we act as a data controller for the personal data of our website visitors and service users. This means those cases where we can decide the purposes and method of processing your personal data.
1.3By using our website, you are agreeing to the terms of this policy.
1.4These privacy rules explain what data we may collect from you, what we will do with that data and explains how you can limit the publication of your information and how you can choose whether or not you would like to receive direct marketing communications.
(c)the legal basis of the processing in each case.
2.2We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your website or service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely monitoring and improving our website and services.
2.3We may process personal data that is provided by you in the course of your use of our website and its services ("service data"). The service data may include your name, email address, home address and contact telephone number and details of your financial situation. The service data may be processed for the purposes of operating our website, providing our services, introducing you to third party service providers who are able to assist you with your requirements, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely the performance of the services you have requested through the website, or the monitoring and improving our website and services.
2.4We may process information contained in any enquiry you submit to us regarding services you may require ("enquiry data"). The enquiry data may be processed for the purposes of introducing you to third party service providers who are able to assist you with your requirements. The legal basis for this processing is either your specific consent or where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely the performance of the services you have requested and monitoring and improving our website and services.
2.5We may process any of your personal data identified in this policy where necessary for administrative purposes including in the exercise or defence of legal claims. The legal basis for this processing is our legitimate interests, namely for administrative record keeping, processing transactions and maintaining business records or for the protection and assertion of our legal rights.
2.6If you supply any other person's personal data to us, you must do so only if you have the authority of such person to do so and you must comply with any obligations imposed upon you under the Data Protection Regulations.
3.1We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our holding company and its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2We may disclose your personal data to third party service providers who are able to offer the services which you have requested.
3.3We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or to exercise or defend legal claims.
3.4We may pass your personal information to credit reference agencies or other agencies that provide services to verify your identity or for any other checks or searches required by legislation or our regulators relating to money laundering. These agencies may keep a record of any search that they do.
3.5We may outsource or contract the provision of IT services to third parties. If we do, those third parties may hold and process your personal data. In these circumstances, we will require that the IT supplier only processes your personal data for us, as directed by us, and in accordance with the Data Protection Regulations.
3.6If we sell all or part of our business, we may pass your personal data to the purchaser. In these circumstances, we will require the purchaser to contact you after completion of the sale to inform you of the identity of the purchaser.
3.7In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your legal interests or the legal interests of another person.
4.2We are not aware of any current circumstances where your personal data may be transferred to any country outside the EEA.
4.3You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5.2Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose. This means that unless there is a good reason to do so we won't keep your personal data more than 6 years after our business relationship has ended.
5.3Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your legal interests or the legal interests of another person.
6.3We may notify you of changes to this policy by email or through the private messaging system on our website.
7.3You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data, as described below (clause 7.13).
8.1A cookie is a small file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser asking permission to be placed on your computer's hard drive. The file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
8.2Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.1We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our services in order to tailor them to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
9.2Overall, cookies help us provide you with a better experience, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
9.3You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our services.