When we provide our services to you, we will collect personal information about you [and others] and we want to be open and transparent with you as to the types of information we collect about you, why we collect it, how we use it and who we may share it with.
The data controller of your personal information is Simon Roberts, Foinaven Asset Management Ltd, Reg Office 51 St John Street, Ashbourne, Derbyshire, DE6 1GP, Registered company number 05045645 (“we”, or “us”, or “our”).
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Notice in the ‘How to contact us’ section.
We may ask you to provide personal information by filling in hard copy forms and documents or by corresponding with us by phone, e-mail, letter or otherwise or during the course of our meetings with you.
|Types of personal information||Why we collect it|
|Identity details including your name and date of birth.We may ask for copies of identity documents in which case we may collect details including your place of birth and residential address.||
|Your contact details including your name, postal, phone and email address(es) and other personal details about you including your title, job title, marital status and date of birth.||
|Financial information relating to you, including pension contributions and current value, salary, bank account balances, credit card balances details of investments and payment card details.||
|Details of your dependents (name, address and date of birth)||
|Details of contact that we have had with you such as meetings with you, fact-finding discussions and documentation, recommendations, referrals and quotes.||
|Details of services you have received.|
|Client experience and other feedback and information you provide to us.||
Please see section below entitled “When we record communications” for more information.
|Information about complaints and incidents.|
|Recordings of calls we receive or make.|
|All of the personal information described above.||
Depending upon the types of products and services you require, we may also need to collect information from and about you which the law considers to be sensitive, such as data about your physical or mental health, which we refer to as “special category personal data”. The special category personal data that we may ask you to provide, and the reasons why we ask you to provide it, are as follows:
|Types of special category personal data||Why we collect it|
|Information about your physical or mental health or condition.||Certain products and services that you request may require this information. Specifically, in order for us to advise you on and to submit applications for health or life insurance products and services, we will need to collect information relating to your physical and mental health in order to obtain accurate quotes and to advise on the suitability of products (as insurance premiums and eligibility for products will in part depend on your physical and mental health). We will usually collect this information in the course of meetings with you, on specific questionnaires or in the process of completing an application form for such products and services.|
|Information about your sex life or sexual orientation.||Some providers may ask for this information in the course of your application for their products or services. We will never ask for this information for our own purposes.|
|Information about your racial or ethnic origin||Some providers may ask for this information in the course of your application for their products or services. We will never ask for this information for our own purposes.|
We will only process the special category personal data listed above with your explicit consent. We ask for your consent to the processing of this data at the end of this Agreement. You may choose not to provide us with this consent.
However, please note that if you do not provide us with your consent to collect and process the information listed in the table above:
In some circumstances, we may receive information about you from third parties. In particular, we will receive information about you from Credit Reference Agencies and Fraud Prevention Agencies. This may include details of the products and services you have applied for, those lenders, finance and credit organisations with whom you have (and have had) an agreement with, the amounts advanced, the amount and frequency of repayments and whether you have made your repayments on time and in full. This will help us make the best possible assessment of your financial situation before we decide whether we can provide you with our services and/or recommend any specific products and services. It is in our legitimate interests to process your personal information for this purpose. We may also ask you to provide Letters of Authority to allow us to receive information about you from providers.
We, and persons acting on our behalf, may record and/or monitor communications (including telephone conversations over landlines and mobile phones, emails, instant messaging, chat rooms, fax and other electronic communications) between our staff and you. We only record communications between us in order to comply with our legal and regulatory requirements – as a regulated financial adviser, the law requires us to record these communications.
We may disclose your personal information to the following categories of recipients:
(i) as a matter of applicable law or regulation (including where we are required by law to provide information to organisations such as HMRC),
(ii) to exercise, establish or defend our legal rights, or
(iii) to protect your vital interests of those of any other person; and
Our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. In respect of the personal information and the purposes for which we may process your personal information which are set out in this Notice, we have confirmed the legal basis upon which we collect and process your personal information in the ‘What type of personal information will be processed and why?’ section above.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you or with your explicit consent, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
You have the following data protection rights:
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
We retain personal information we collect from you where we have an ongoing legitimate need to do so, for example:
When we have no ongoing legitimate need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We may change or update this Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
If you would like to contact us in relation to this Notice or if you have any other questions in respect of our processing of your personal information, please Simon Roberts, Foinaven Asset Management Ltd, 42a St John Street, Ashbourne, Derbyshire, DE6 1GH, 01335 344446, firstname.lastname@example.org.