Using your Information
Privacy Policy
Your rights, your information and how we use it
DATA Wealth Management LLP is committed to protecting your personal information.
Our Privacy Policy contains important information about the personal details we collect from you; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.
In the future we may need to make changes to our Privacy Policy, if there are important changes that we need to make, such as changes to where your personal data will be processed; we will contact you to let you know.
This version of our Privacy Policy was last updated 16th November 2021.
Who we are
We are DATA Wealth Management LLP, a Restricted Financial Advice firm authorised and regulated by the Financial Conduct Authority.
This Privacy Policy applies to DATA Wealth Management LLP and the products and services we offer to our Clients.
How to contact us
If you have any questions about our Privacy Policy or the information we collect or use about you, please contact Paul Freeth at the following address or by email:
DATA Wealth Management LLP,
Courtyard Barn, Binham Road,
Langham,
Holt,
NR25 7AB
Email: paulfreeth@dwmllp.com
Information we collect and use
Information about you that we collect, and use includes:
• Information about who you are e.g. your name, date of birth and contact details
• Information connected to the product or service with us e.g. your bank account details
• Information about your contact with us e.g. meetings, phone calls, emails / letters
• Information classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations
• Information you may provide us about other people e.g. joint applicants or beneficiaries for products you have with us
• Information on related children e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)
Where we collect your information
We may collect your personal information directly from you, from a variety of sources, including:
• In a fact-find questionnaire completed at our initial meeting
• Our Client agreement
• Application forms for a product or service
• Phone conversations with us
• E-mails or letters you send to us
• Review meetings with us
If you are a member of your employer’s pension scheme, any information we collect and use will most likely have been provided by them on your behalf.
We may also collect personal information from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.
What we collect and use your information for
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair, and lawful to do so. We will collect and use your information only where:
• You have given us your permission [consent] to send you information about products and services offered by selected third parties we have chosen to work with which we believe may be of interest and benefit to you
• It is necessary to enable us to provide the product or service you have requested [contract] e.g. if you will be investing in a pension or investment arrangement, we will require some personal information including your name, address, date of birth, bank account details
• It is necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Statements, tell you about changes to Terms and Conditions or for the detection and prevention of fraud
• It is in the legitimate interests of DATA Wealth Management LLP to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from your product or investment; where we need to process your information to better understand you and your needs so we can send you more relevant communications about the products you have with us and to develop new products and services; where we use artificial intelligence or computer algorithms to improve the products and services offered to you
• It is in the legitimate interests of a third party e.g. sharing information with your employer, your accountant, or your solicitor where relevant to your financial planning objectives
If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.
Who we may share your information with
We may share your information with third parties for the reasons outlined in 'What we collect and use your information for.
These third parties include:
• Product Providers
• Your employer, your accountant, or your solicitor
• Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers e.g. research, consultancy or technology companies; or companies who can help us in our contact with you, for example an internet service provider
• Our regulators and Supervisory Authority: The Financial Conduct Authority (FCA), the Information Commissioner’s Office for the UK (the ICO)
• Law enforcement, credit and identity check agencies for the prevention and detection of crime
• HM Revenue & Customs (HMRC) for the prevention of tax avoidance
We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.
Where your information is processed
The majority of your information is processed in the UK and European Economic Area (EEA).
(Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.)
How we protect your information
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. The Partners also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.
Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity, and availability of your information.
How long we keep your information
We will keep your personal information only where it is necessary to provide you with our products or services while you are a customer.
We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.
Your individual rights
You have several rights in relation to how DATA Wealth Management LLP uses your information. They are the following:
• Right to be informed
You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with – we do this in our Privacy Policy and privacy notices.
• Right of access
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR). This can be done at no cost to you and we are obliged to respond within 30 days of your original request.
• Right to request that your personal information be rectified
If your personal information is inaccurate or incomplete, you can request that it is corrected.
• Right to request erasure
You can ask for your information to be deleted or removed if there is not a compelling reason for DATA Wealth Management LLP to continue to have it.
• Right to restrict processing
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.
• Right to data portability
You can ask for a copy of your personal information for your own purposes.
• Right to object
You can object to DATA Wealth Management LLP processing your personal information where: it’s based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.
• Rights related to automatic decision making including profiling
You have the right to ask DATA Wealth Management LLP to give you information about its processing of your personal information.
How to make a complaint
We will always strive to collect, use, and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy, please let us know and we will do our utmost to correct matters.
Please contact: Paul Freeth at the following address, email or phone:
DATA Wealth Management LLP,
Courtyard Barn, Binham Road,
Langham,
Holt,
NR25 7AB,
Email: paulfreeth@dwmllp.com
07557 958 272
If we are unable to correct matters to your satisfaction and you are still unhappy, you can complain to the Supervisory Authority for data collection and use.
Their contact details are:
The ICO: www.ico.org.uk