Privacy Notice

How we collect your data

We obtain information about you from information supplied by you directly to us by telephone, face to face meetings or email, from information requested from financial product providers or information you provide via our websites.

What information is being collected

We collect the information required to provide financial advice, apply for financial products and/or to provide you with our ongoing service.

We use many different kinds of personal information, and group them together like this.

Contact

Where you live and how to contact you.

Financial

Your financial position, status and history.

Socio-Demographic

This includes details about your work or profession, age and nationality.

Social Relationships

Information about your family

Contractual

Details about the products or services we provide to you.

Communications

What we learn about you from letters, emails and conversations between us.

Open Data and Public Records

Details about you that are in public records, such as the Electoral Register, and information about you that is openly available on the internet.

Usage Data

Other data about how you use our products and services.

Documentary Data

Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence or birth certificate.

Special types of data

The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Trade union membership
• Health data including gender
• Criminal convictions and offences

Consents

Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you.

National Identifier

A number or code given to you by a government to identify who you are, such as a National Insurance number.

If you choose not to give personal information

We may need to collect personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations or obtaining the products and services requested. It could mean that we cancel a product or service you have with us. We will notify you at the time if this is the case.

Any data collection that is optional would be made clear at the point of collection.

Why we process your data

We may use your information to:

• to carry out our obligations arising from any contracts entered into by you and us to:
• provide you with financial advice;
• act as your agent to purchase financial services products;
• provide our Precision ongoing client service;
• comply with any legal or regulatory obligation to which we are subject;
• process any remuneration you have agreed to pay your financial adviser;
• carry out any relevant conflict checks, anti-money laundering and sanctions checks and fulfilling our obligations under any relevant anti-money laundering law or regulation (including under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017);
• provide a customised experience via our Wealth Platform client portal or other websites;
• deal with any complaints which may arise in the future;
• to provide you with information about other services we offer that are similar to those that you have already used or enquired about;
• seek your views or comments on the services we provide;
• notify you of changes to our services;
• send you communications which you have requested and that may be of interest to you;
• prevent illegal activity or to protect our interests;
• fulfil the legitimate interests of the company.

Legitimate interests

One of a number of lawful reasons that we can use (or ‘process’) your personal information is called ‘legitimate interests’. Broadly speaking Legitimate Interests means that we can process your personal information if:

• We have a genuine and legitimate reason and we are not harming any of your rights and interests

This means when you provide your personal details to us we may use your information for our legitimate business interests to carry out our work providing you with professional financial advice and access to high quality financial products. Before doing this though, we will also carefully consider and balance any potential impact on you and your rights.

Your interests

When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

If you would like more information on how we process data under legitimate interests please contact us on the details above.

How we share your data

We will not sell or rent your information to third parties. We will not share your information with third parties for marketing purposes

Your personal data will be treated as strictly confidential and will be shared only with our carefully selected service providers for the purposes described in this statement, any financial product provider from whom products or services are/will be purchased, any third party you ask us to share your data with and other parties where we may be required to provide such information, for example our regulator the Financial Conduct Authority.

Depending on the instructions we receive from you, we may also pass some of your data to other professional advisers to enable us to provide advice most suited to your circumstances. Usually, this would be referrals to accountants, solicitors, tax advisers and sometimes specialist advisers in the financial and insurance industry where you may benefit from the expertise of such third parties. We, and any third party specialist advisers to whom we introduce you, will pass your data to organisations when you agree to purchase and amend policies and products.

Third Party Service Providers working on our behalf:

We may pass your information to our third-party service providers for the purposes of completing tasks and providing services to you on our behalf. However, 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. Please be reassured that we will not release your information to any third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime. Your data may be passed to Sandringham Financial Partners who provide our regulatory framework for the purpose of fulfilling any contract we have with you. Your data may also be shared with another financial adviser within Sandringham who will act as a locum should your adviser be unavailable for any reason.

Third Party Product Providers we work in association with:

We work closely with various third-party financial product providers to bring you a range of quality and reliable financial products and services. When you enquire about or purchase one or more of these products, the relevant third-party product provider will use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them. In some cases, they will be acting as a data controller of your information and therefore we advise you to read their Privacy Policy. These third-party product providers will share your information with us which we will use in accordance with this Privacy Policy.

Your data may also be transferred to the Financial Conduct Authority or any other statutory, governmental or regulatory body as well as other parties including auditors or insurers if required.

The third parties we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you.

Transfer outside of the EU

To provide services to you we may be required to pass your personal information to product and service providers located outside of the European Economic Area (EEA) in countries that do not have Data Protection Laws equivalent to those in the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

To do this we’ll use one of these safeguards:

• Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
• Put in place a contract with the recipient that means they must protect it to the same standards as the EEA.
• Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.

Disclosure of your information

Notwithstanding any terms to the contrary, we may disclose your personal data to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets; or
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or
• to protect the rights, property, or safety of our business, our service, our users and any third party we interact with to provide the Service.

How long we will keep it

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example, our regulator, the Financial Conduct Authority require that records of our advice are kept for certain periods, in most cases this is at least 5 years but, in some cases, e.g. relating to pension transfers, may be indefinitely). We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is necessary to fulfil our legal and statutory obligations. As FCA regulated advisers we are required to retain records relevant to our advice to you and this can supersede your right to have all data deleted under the General Data Protection Regulation. If you require details of the statutory retention periods for the differing product types and classes of data please ask us.

Your choices

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about the products and services we feel may be of interest to you, then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information.

We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted. You can change your marketing preferences at any time by contacting us by email: mail@hugginswm.co.uk or telephone on 01227 870087.

Your Rights

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the address above. Please note: For any access request made after 25 May 2018 that is deemed excessive or especially repetitive, we may charge a ‘reasonable fee’ for meeting that request. Similarly, we may charge a reasonable fee to comply with requests for further copies of the same information. (That fee will be based upon the administrative costs of providing the information).

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

You have the right to ask us to erase the personal data you have provided to us. We will carry out this request where it does not conflict with any legal, regulatory or contractual obligations we may have. We will discuss this with all clients who request and data to be deleted.

You have the right to withdraw your consent for us to process your personal data however doing so may affect our ability to fulfil our contractual obligations or obtain the products and services requested. If you do withdraw your consent, we may still be able to process some of the data that you have provided to us on other grounds, we will notify you upon request should this be the case.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking/ticking certain tick boxes we use to collect your data. You can also exercise the right at any time by contacting us using our contact details set out below.

Our websites may, from time to time, contain links to and from the websites of our partner product providers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

How to complain

Please let us know if you are unhappy with how we have used your personal information. You can contact us at by emailing mail@hugginswm.co.uk or by writing to:

Huggins Wealth Management Ltd Canterbury Innovation Centre University Road Canterbury CT2 7FG

Alternatively, you can telephone 01227 870087.

You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern. https://ico.org.uk/concerns/

How we secure your data

Non-sensitive details (your email address etc.) may be transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. We use industry standard physical, technical, and logical security measures to protect your Data. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Cookies

Cookies are small bits of text that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you and can then tailor what you see on the screen.

Some of the cookies we use:

Certain cookies are necessary in order for you to use our websites. These are used ‘in-session’ each time you visit and then expire when you leave the site. They’re not stored on your computer and they don’t contain any personal data. However, you can delete them via your browser if you wish to, but this may restrict the functions that you’re able to carry out on our sites.

Session cookies

These enable you to carry out some essential functions on our sites, they also help by minimising the need to transfer information across the internet. They are not stored on your computer and they expire when you terminate your browser session or logout of certain areas.

Analytics

We like to keep track of what pages and links are popular and which ones don’t get used so much to help us keep our sites relevant and up to date. It’s also very useful to be able to identify trends of how people navigate (find their way through) our sites and help us provide a more friendly solution.

Third-party cookies

Google Analytics tracking (and most web tracking software) uses cookies in order to provide meaningful reports about site visitors. However, Google Analytics cookies do not collect personal data about website visitors.

Managing your cookies

You’ll find more information about cookies at www.allaboutcookies.org, which gives details on how to delete cookies from your computer. For information on how to do this on your mobile phone browser, please see your handset manual.

Cookies are used on our site to ensure that we give you the best experience on our website. If you continue without changing your settings, we’ll assume that you are happy to receive all cookies on our website. Some cookies are essential so you can move around the website and use its features. Without these cookies, some services you’ve asked for can’t be provided. These cookies don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet.

Changes to our Privacy Policy

We keep this Policy under regular review and we reserve the right to modify this Privacy Policy at any time. You will be notified of any future changes we may make to our Privacy Policy and these will be made available to you using our website. Your continued use of the services and our website shall be deemed your acceptance of the varied Privacy Policy.