The Wealth Office Ltd is a company registered in Scotland. We are committed to protecting your privacy and personal information. Your personal privacy and security of your personal data are important to us.

We believe you should be aware of who we are, the information we may collect about you and what we do with that information.

Overview

This policy applies when you visit and interact with thewealthoffice.co.uk website and to the financial services that are provided to you by The Wealth Office Ltd.  It contains information about:

• how we use your data
• what personal data we collect
• how we ensure your privacy is maintained
• your legal rights relating to your personal data.

 Introduction

This privacy policy will inform you as to how we look after your personal data when you visit thewealthoffice.co.uk. In addition, this privacy policy will inform you about your privacy rights and how the law protects you.

About us

This website is owned and operated by The Wealth Office. When we refer to The Wealth Office, we mean The Wealth Office Ltd, company no. SC632922.

When we refer to “The Wealth Office”, “we”, “us” or “our”, we are referring to The Wealth Office Ltd. In accordance to our service, we collect, use, retain and are responsible for personal data about you. We are required to comply with data protection regulations to ensure your personal data is kept safe.

Controller

The Wealth Office Ltd is the controller and responsible for your personal data.

Contact details

If you have any questions regarding this privacy policy, please contact us using the details set out below:

The Wealth Office

Email: enquiries@thewealthoffice.co.uk

Post: 220 St Vincent Street, Glasgow, G2 5SG

Phone: 0141 739 5466

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).

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Privacy policy changes and your duty to inform us of changes

This version was last updated on 4^th June 2020.

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.

Data we collect

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 follows:

In the course of providing our service to you, we may collect the following types of personal data:

• Your contact details including phone numbers, addresses and email address
• Your identity including passport and other official identity document details
• Your personal financial information covering your assets and liabilities, income and expenditure
• Your employment status
• Your lifestyle including hobbies and holidays
• Your health including confidential medical details, smoker status and details of any medication you take
• Details of any vulnerability including loss of capacity to make decisions
• Details of your dependents and/or beneficiaries under a financial policy. If you are providing information about another person we expect you to ensure that they know you are doing so and have given their consent to their information being provided to us as well provide them with a copy of this document
• Product details including pension plans, investments, insurance contracts & mortgages
• Details of your attitudes to investment risk and future financial goals

Data we collect from other sources

We may also collect personal data from other sources when providing our services.

When obtaining this information from an external party, it is their responsibility to explain that they will be sharing personal data with us. It also their responsibility, where necessary to ask for permission before sharing information.

The personal data we obtain from other sources may include the following:

• From product providers – product information
• From introducers, such as solicitors & accountants – your personal contact information and a background of your circumstances.
• From identification and verification checking agencies – identity information & sanction information.

Website usage information and automatically collected information

When visiting The Wealth Office website, we may use cookies and other technologies to automatically collect the following information for analytical purposes, but your identity will remain private:

• Technical information, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors
• Information about your visit, including the websites you visit before our websites and products or services you viewed or searched for
• The number of visits, length of visits to certain pages, pages viewed, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page
• Similar information for additional content that can be accessed from website pages, such as opening, or printing documents or which videos are played and for how long

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 for services 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

You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below in a table format a description of all the ways we plan to use your personal data and the legal bases upon which we collect and use your personal data:

 

Reason for processing	Type of data	Lawful bases for processing
Sending you a newsletter via email by using the ‘Sign up to our newsletter’ function on the Website Providing your name, telephone number and email address in the ‘contact us’ form on the website When you contact us via email by clicking on the email address links or ‘get in touch’ links on the Website	Identity Contact Profile Marketing and communications	Consent
Performing our duties as your financial planner	All information necessary to act as your financial planner, including, but not limited to: Identity Contact Profile Financial Employment	Performance of contract
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Special category data

Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’. This is data concerning your health, racial or ethnic origin, genetic data and sexual orientation. This also includes data relating to criminal convictions or offences are also subject to additional levels of protection.

We may process:

• Health information and lifestyle information when providing intermediary services in relation to a protection insurance product
• Criminal conviction or offence information when providing intermediary services in relation to a general insurance product

The lawful basis for processing this information is set out in the above table, we will be processing it either for the purpose of advising on, arranging or administering a contract or to comply with financial regulations.

Marketing

We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you.

We use the following personal data control mechanisms:

• Promotional offers from us

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.

You will receive marketing communications from us if you have requested information from us by completing forms or submitting an enquiry via our website.

• Third-party marketing

We will share your personal data with our marketing agency for marketing purposes.

Opting out

You can opt out of receiving marketing at any time.  If you wish to amend your marketing preferences, please contact us by:

Email: enquiries@thewealthoffice.co.uk

Post: 220 St Vincent Street, Glasgow, G2 5SG

Phone: 0141 739 5466

In addition, you can opt out of receiving marketing at any time by clicking the ‘unsubscribe’ link at the bottom of every marketing email we send or by amending your preferences on our Service Agreement.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Disclosing your information to third parties

We routinely disclose your personal data to third parties as follows:

• We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers)
• We may also disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable)
• 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
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets
• 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 apply our client agreement/service charter
• To protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with the to provide our website in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be of interest to you.

Data security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way.

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.

How long do we keep hold of your data?

During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.

We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:

 

Types of record	Retention period
Client data where advice has been provided or a regulated product has been provided.	We will retain your personal data until your date of death.
Client data where you made an enquiry, but no advice or regulated products were provided.	We retain your personal data for 12 months from the date of our last contact with you.

 

These are minimum periods, during which we have a legal obligation to retain your records.

We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so.

You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

 

Disclosing 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 under ‘How we use your personal data’.

• 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.
• Regulatory Agencies for financial services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit them to process your personal data for specified purposes and in accordance with our instructions or in accordance with applicable laws.

 

Where do we store your data?

All of the information that We hold about you is stored on our secure servers within the European Economic Area (EEA).

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

Your legal rights

Under general data protection regulations, you have a number of important legal rights relating to your personal data:

• To access your personal data
• To require us to correct any mistakes in the information which we hold
• To require the erasure of personal data concerning you in certain situations
• To receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• To object at any time to the processing of personal data concerning you for direct marketing
• To object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• To object in certain other situations to our continued processing of your personal data
• To restrict the processing of your personal data in certain circumstances
• To compensation for damages caused by our breach of any data protection laws

If you would like to exercise any of these rights, please:

• Let us have enough information to identify you (e.g. account number, username, registration details)
• Let us have proof of your identity and address (e.g. a copy of your driving licence or passport and a recent utility or credit card bill)
• Let us know the information to which your request relates, including any account or reference numbers

Changes to our privacy policy

We reserve the right to modify this policy at any time. Any changes we may make to our policy in the future will be notified and made available to you using the website.

Your continued use of the services and the website shall be deemed your acceptance of the varied privacy policy.