Privacy Policy

This Policy explains when and why we collect personal information about people who enquire about or utilise the services of our company. The policy also explains how we use that information, the conditions under which we may disclose information to others and how we keep personal information secure.

When using the terms “personal data”, “personal information” or simply “your information” in our Privacy Policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. The pieces of information are also known as “identifiers” and include a name, an online identifier, or a reference to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. It does not include data where the identity has been removed (anonymous data).

When using the term “processing”, we mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (so practically anything we do to your personal data is processing!)

What type of information is collected?

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, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• 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 this website.
• Profile Data includes your username and password to access our client portal, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services, and navigate through the website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share ‘Aggregated Data’ such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

In most cases, we do not collect any ‘Special Categories’ of personal data about you (this includes 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). Nor do we collect any information about criminal convictions and offences. However, in limited cases, we may need to collect such categories of data and if so will rely on a lawful basis (such as your explicit consent) to ensure that we can lawfully process that data only as may be required as part of an ongoing business relationship you have with us.

How we collect information from you

We collect information about you when you:

• use our website ‘contact us’ form to enquire about products and services
• meet with an International financial adviser (at this meeting a Financial Adviser may ask you questions which will be recorded onto our client on-boarding documents including for example our Fact-Find forms, Risk Profile Questionnaires or Client Agreements
• call our office to enquire about our services
• enter into a formal business relationship with us

Other than from information you enter on our website, or provide on our documentation, we may also collect your personal data from documents you provide to us. For example, we may also ask you to provide evidence of your identity such as asking for a copy of your passport, driving licence, proof of residence or income. We are required to ask for this information to comply with anti-money laundering (AML) legislation.

Monitoring

Please note that if you communicate with us electronically, including by e-mail, telephone, this communication may be monitored and/or recorded to protect the interests of our business and our customers. This includes for the purposes of maintaining customer/service quality standards, detection of and/or prevention of crime and to ensure that we comply with legal obligations.

If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of a contract 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 (for example, to provide you with our 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 we use your personal information

We use personal information about you in connection with the following purposes:

Provision of services and account management:

• to provide you with the information, products, and services that you have requested from us.
• to complete any transaction you are undertaking with us;
• to meet a legal or regulatory obligation.

Service improvements:

• to ensure that content from our site is presented in the most effective manner for you;
• to administer our site and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to notify you about changes to our service;
• as part of our efforts to keep our site safe and secure;

Direct Marketing:

• to provide you with information about other services we offer that are similar to those that you already have or have enquired about;

Where you are an existing client, we will rely on our legitimate interests as the lawful basis for processing your personal information for the purposes of direct marketing. To this end, it may be necessary to process your information so we can directly market in our legitimate interest. In addition, we consider it reasonable for you to expect you may receive marketing material from us in the same methods we normally communicate with you (e.g. via email) and that there is no disproportionate impact to your individual privacy rights in this case.

How long we keep your information for

We retain your information only for as long as is necessary and we are required to for regulatory purposes for which we process the information as set out in this Privacy Policy. Records are held in electronic and physical formats.

Retention periods are determined based on the type of record, the nature of the record and activity and the legal or regulatory requirements that apply to those records. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

However, we may retain your personal data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or where we have a legitimate interest to do so for example, to manage your pension, tax and social security obligations etc.

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 using 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 using 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;
• 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 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 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 override 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 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 using the above details. On 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 using the above 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 information we hold about you. You can exercise this right at any time by contacting us using 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 mean 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

You also have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of our rights has taken place, if that is based in the EEA.

Sharing your personal information

We may pass your information to business partners, administration centres, third party service providers, 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 custodial platforms

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 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.

Transferring your information outside of the European Economic Area

There may be instances whereas part of the services offered to you by the Company, information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). The EEA includes the European Union countries as well as Iceland, Liechtenstein and Norway. Transfers outside of the EEA are sometimes referred to as ‘third country transfers’.

This may happen if any of our Platform providers are located in a ‘third country’ outside of the EEA. If we transfer your information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Policy. This may require us to take certain additional steps to ensure that appropriate safeguards are in place if that third country is not deemed by the European Commission to offer an adequate level of protection for your privacy rights, which may include use of contractual safeguards to allow you to be able to enforce your rights and ensure these are preserved. In certain circumstances, we may need to ask you for your explicit consent to such third country transfers, and will always do so in writing and giving you full information about why we need your consent and your right to withdraw that consent at any time (together with the consequences of withdrawal).

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see further information on the European Commission’s website: European Commission: EU-US Privacy Shield.

If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

Keeping your information safe

We take our responsibility to look after your personal information and privacy seriously. In today’s world, we have all seen a growing trend in cybercrime and security breaches. We have a number of security measures in place to help prevent fraud and cybercrime.

If we become aware that a personal data breach has occurred and is likely to result in a high risk to the rights and freedoms of our clients, business partners or employees, we will inform them without undue delay.

We educate and train our employees on our information security, fraud prevention and privacy obligations annually. Information Security awareness also forms part of our new employee induction program.

We also educate our employees in identifying potential financial crime and internal fraud; any suspicious activity is reported to the relevant Financial Intelligence Unit.

Use of Cookies:

As described above, part of our processing of your personal data (as defined therein) involves us collecting certain data which we have called “technical data” for ease of reference and convenience. One way in which we collect this data is using cookies, and we do it for the key purpose of giving you a better browsing experience, developing our website and making it more attractive and useful to our clients and customers, and generally improving our overall service and expanding our international reach.

For general web-browsing of this website, your personal data is not revealed to us, although certain statistical information is available to us via our internet service provider as well as through the use of special tracking technologies. Such information tells us about the pages you are clicking on or the hardware you are using, but not your name, age, address or anything we can use to identify you personally. Provided you cannot be identified, it will not be personal data.

By using our website, you consent to storage and access to cookies and other technologies on your device, in accordance with this Cookie Policy.

What are cookies?

Cookies are a feature of web browser software that allows web servers to recognize the computer or device used to access a website. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

What are the different types of cookies?

A cookie can be classified by its lifespan and the domain to which it belongs.

By lifespan, a cookie is either a:

• session cookie which is erased when the user closes the browser; or
• persistent cookie which is saved to the hard drive and remains on the user’s computer/device for a pre-defined period of time.

As for the domain to which it belongs, cookies are either:

• first-party cookies which are set by the web server of the visited page and share the same domain (i.e. set by us); or
• third-party cookies stored by a different domain to the visited page’s domain.

What cookies do we use and why?

We list all the cookies we use on this website below. They include cookies set by our web developers (first-party cookies), and those set by others (third-party cookies). We use session and persistent cookies on our website.

Cookies are also sometimes classified by reference to their purpose. We use the following cookies for the following purposes:

• Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that allow us to comply with legal obligations.
• Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it, as well as dates and times they visit, or how long they visit. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, and remember your preferences for example, your choice of language or region. Other cookies may be used when you submit data to us through a form such as those found on contact pages, and may be set to remember your user details for future correspondence.
• Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed, as well as time spent on our website, and the websites visited just before and just after our website. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

In general, we use cookies and other technologies (such as web server logs) on our website to enhance your experience and to collect information about how our website is used. This information is put together (‘aggregated’) and provides general and not individually specific information. None of this information is therefore associated with you as an individual and the cookie-related information is not used to identify you personally. It is therefore anonymised and ‘de-identified’. The pattern data is fully under our control and these cookies are not used for any purpose other than those described here.

We will retain and evaluate information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive. The information also helps us to understand which parts of this website are most popular and generally to assess user behaviour and characteristics to measure interest in and use of the various areas of our website. This then allows us to improve our website and the way we market our business.

This information may also be used to help us to improve, administer and diagnose problems with our server and website. The information also helps us monitor traffic on our website so that we can manage our website’s capacity and efficiency.

Google Analytics Cookies

This website uses a web analytics service provided by Google, Inc. (“Google”).

We use Google Analytics to track your preferences and also to identify popular sections of our website. Use of Google Analytics in this way enables us to adapt the content of our website more specifically to your needs and thereby improve what we can offer to you.

Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

In particular Google Analytics tells us

• your IP address (last 3 digits are masked);
• the number of pages visited;
• the time and duration of the visit;
• your location;
• the website you came from (if any);
• the type of hardware you use (i.e. whether you are browsing from a desktop or a mobile device);
• the software used (type of browser);
• your general interaction with our website; and
• your search history (if you decide to use the search bar at the top of our page).

As stated above, cookie-related information is not used to identify you personally, and what is compiled is only aggregate data that tells us, for example, what countries we are most popular in, but not that you live in a particular country or your precise location when you visited our website (this is because we have only half the information – we know the country the person is browsing from, but not the name of person who is browsing). In such an example Google will analyse the number of users for us, but the relevant cookies do not reveal their identities.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Google Analytics, its purpose and function is further explained on the Google Analytics website.

For more information about Google Analytics cookies, please see Google’s help pages and privacy policy: Google’s Privacy Policy and Google Analytics Help pages. For further information about the use of these cookies by Google click here.

Other Google Services

We also make use of other technologies offered by Google, such as advertising services. In doing so, we allow Google to place cookies on our website for this purpose. Google uses a variety of domains to set cookies used in their advertising products and it may not be immediately apparent these domains are associated with Google (e.g. such as “gstatic.com” or “doubleclick.net”). For more information about the types of cookies used by Google click here.

What if you don’t agree to us monitoring your use of our website (even if we don’t collect your personal data)?

Enabling these cookies is not strictly necessary for our website to work but it will provide you with a better browsing experience. You can delete or block the cookies we set, but if you do that, some features of this website may not work as intended.

Most browsers are initially set to accept cookies. If you prefer, you can set your browser to refuse cookies and control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your device and you can set most browsers to prevent them from being placed. You should be aware that if you do this, you may have to manually adjust some preferences every time you visit an Internet site and some services and functionalities may not work if you do not accept the cookies they send.

Advertisers and business partners that you access on or through our website may also send you cookies. We do not control any cookies outside of our website.

If you have any further questions regarding disabling cookies you should consult with your preferred browser’s provider or manufacturer.

In order to implement your objection it may be necessary to install an opt-out cookie on your browser. This cookie will only indicate that you have opted out. It is important to note, that for technical reasons, the opt-out cookie will only affect the browser from which you actively object. If you delete the cookies in your browser or use a different end device or browser, you will need to opt out again.

To opt out of being tracked by Google Analytics across all websites, Google have developed the Google Analytics opt-out browser add-on. If you would like to opt out of Google Analytics, you have the option of downloading and installing this browser add-on which can be found under the link: http://tools.google.com/dlpage/gaoptout.

If you do not accept changes which are made to this Cookie Policy, or take any measures described above to opt-out by removing or rejecting cookies, you may continue to use this website but accept that it may not display and/or function as intended by us.

We will always interact with you in a safe, secure and consistent manner