Privacy and Data
Changes to the privacy notice and your duty to inform us of changes
The data protection law in the UK and Channel Islands changed on 25 May 2018. This privacy notice may continue to change. 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.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
- We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender, tax identifier, passport number.
- Contact Data includes home address, mailing address, email address and telephone numbers
- Financial Data includes bank account details, and in some cases financial status and history. Transaction Data includes details about payments and other details of products and services.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and
other technology on the devices you use to access our systems.
- Profile Data includes your username and password, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
On some occasions, we might collect or process Special Categories of Personal Data about you. (Special Categories of Personal Data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). In Praemium terms this would be limited to health data where the advisor opts to collect such information. Also, for AML purposes we collect information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract that we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you to provide you with goods or services. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you or your business including through:
- Financial Advisers. May give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data they provide when you:
- apply for or use our products or services;
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services; o request marketing to be sent to you;
- request that we update your data;
- take part in a promotion or survey; or
- give us some feedback.
- Other companies within the Praemium Group
- Other third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below
- Technical Data from the following parties:
- data providers such as product providers
- search information providers based inside OR outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as bank account and address verification engines.
- Identity and Contact Data from data brokers or aggregators, such as credit reference agencies.
- Identity and Contact Data from publicly available sources, such as Companies House based inside the EU.
- Technical Data from the following parties:
How we use your personal data
- We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract that we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You
have the right to withdraw consent to marketing at any time by contacting us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
If you are our client, we strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get, or ensure that you have provided, your express opt-in consent before we share your personal data with any company outside the Praemium Group for marketing purposes.
You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where we are the Controller of your personal data, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Praemium Group. This may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we will have in place specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Some of our external third parties are based, or store data, outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA.
Where we use providers based in the US, we transfer data to them if they are party to the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield. Please contact us if you would like further information.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will keep your personal information for as long as you are a customer of ours. After you stop being a customer, we may keep your data indefinitely for one of these reasons:
- To respond to any questions or complaints.
- To show that we treated you fairly.
- To maintain records according to rules that apply to us.
- If we cannot delete it for legal, regulatory or technical reasons.
- For research or statistical purposes.
If we do, we will make sure that your privacy is protected and only use it for those purposes. In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the glossary below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
- If you wish to exercise any of the rights set out above, please contact us.
No fee usually required.
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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to respond
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.
Data Protection Officer
Full contact details are:
Name: George Harris
Position: Data Protection Officer
Email address: [email protected]
Postal address: 4th Floor, Salisbury House, London Wall, London EC2M 5QQ
Telephone number: 0203 873 5566
You can also email the Data Privacy Team at [email protected]
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), The Jersey Office of the Information Commissioner, can be accessed via www.oicjersey.org. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.