Financial Services – Privacy Policy
The following statement explains our policy regarding the personal information we collect about you.
- About Liberate Wealth Solutions
- Our processing of your personal information
- What marketing activities do we carry out?
- How long do we keep personal information for?
- What is our approach to sending your personal information overseas?
- Your rights
- Contacting Us
- Cookies
- How do we protect your information?
- Google Analytics
- Monitoring
- Hyperlinks
- Updates to this notice
1. About Liberate Wealth Solutions
Liberate Wealth Solutions and Liberate Wealth (Taunton) are committed to protecting the privacy of its users and we therefore ask that you please read our Privacy Policy before providing us with any information about you or any other person (“Personal Information”).
Our use of your Personal Information
Liberate Wealth is a trading name of Liberate Wealth (Taunton) Limited,
Registered address Aintree House, Blackbrook Park, Taunton, Somerset, TA1 2PX.
Liberate Wealth (Taunton) Limited (registered in England & Wales No 03866935) is an Appointed Representative of Liberate Wealth Solutions Limited, which is authorised and regulated by the Financial Conduct Authority.
2. Our processing of your personal information
We will collect and use different personal information about you for different reasons, depending on our relationship with you.
Sometimes we will request or receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership) in order to provide comprehensive advice and deliver health related products to you.
We may also use details of any unspent criminal convictions for fraud prevention purposes during the process of investing money.
Where you provide personal information to us about other individuals (for example, members of your family or other dependants) we will also be data controller of their personal information and we are responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to this notice.
In order to make this notice as user friendly as possible, we have split it into different sections. Please read the section below that best describes your relationship with us and the service you receive from us.
General information such as your name, address, phone numbers, email addresses, date of birth and gender.
- Identification information including passport, driving licence, national identity card (for non-UK nationals), government issued ID verification and address verification documents such as council tax letters or bank statement and evidence of benefit entitlement (this is not an exhaustive list).
- Employment information such as job title, employment history and professional accreditations.
- Financial information relevant to the products we provide, including:
- Bank details
- Financial reviews (fact finds)
- Information relating to your personal finances such as your financial liabilities and assets, income and outgoings.
- Information obtained from carrying out identification checks and checking sanction lists and politically exposed persons (PEP) screening, including bankruptcy orders or where you have been flagged as a PEP, or where you have close links to PEPs.
- Information about your family including information about your dependants.
- Information obtained during telephone recordings.
- Your marketing preferences and details of your customer experience with us.
- Details about any criminal convictions and any related information which has been obtained from our sanctions checks and PEP screening. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.
- Details about your health which are relevant to the service you are receiving, for example where you have disclosed such information to us because it helps understand your risk appetite for investments or other products we may recommend to you.
We will collect information directly from you when:
• you enquire about a service, or general financial advice from Liberate Wealth or apply to invest within one of our investment solutions or recommended products; and
• you contact us by email, telephone and through other written and verbal communications.
We will also collect your personal information from:
- you enquire about a service, or general financial advice from Liberate Wealth or apply to invest within one of our investment solutions or recommended products; and
- you contact us by email, telephone and through other written and verbal communications.
We will also collect your personal information from:
- Other Independent Financial Advisers or introducers where they act as your agent or introducer to Liberate Wealth.
- Other Liberate Wealth group companies.
- Third parties who provide anti money laundering and fraud prevention services who we have appointed to carry out electronic ID checks, sanctions and politically exposed persons checking services.
We will rely on the following “lawful basis” when we process your “personal information”:
- We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to maintain business records, to review our business models, to undertake strategic and operational business analysis of the services we offer, to maintain management information, and for internal audit purposes.
- We need to use your personal information to enter into the product agreement with you for the product in question. For example, we need to use your personal information to set up the services that you are looking to purchase from us.
- We have an advice purpose to use your special categories of personal information and such as assessing suitability, managing accounts and preventing and detecting fraud.
- It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
- We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.
- You have given your explicit consent to our use of your special categories of personal information. We may not be able to assess the suitability of a service without details regarding your health situation.
| Purpose for processing | Lawful basis for using your personal information | Lawful basis for using your special categories of personal information |
| To carry out identification checks | · It is necessary to enter into your service agreement.
· We have a valid business reason (to carry out necessary compliance checks). · We have a legal and regulatory obligation.
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· We have a substantial public interest to prevent or detect unlawful acts (where we suspect fraud).
· It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. · We have your explicit consent. · We need to establish, exercise or defend legal rights. |
| To answer any queries you may have and to provide you with a quote for the service in question. | · It is necessary to enter into your product agreement.
· We have a valid business reason (to communicate with you and ensure that the service is appropriate for your requirements). |
· You have given us your explicit consent.
· Where you apply for services that require suitability advice or an assessment of appropriateness of a service or product. |
| To prevent and investigate fraud. | · It is necessary to enter into your product agreement.
· We have a valid business reason (to prevent and detect fraud and other financial crime).
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· We need to use your information in order to establish, exercise or defend legal rights.
· We have a substantial public interest to prevent or detect unlawful acts (where we suspect fraud). · It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. · We have your explicit consent. |
| To comply with our legal or regulatory obligations.
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· We need to use your information in order to comply with our legal obligations.
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· We need to use your information in order to establish, exercise or defend legal rights.
· We have a substantial public interest to prevent or detect unlawful acts (where we suspect fraud). · It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. · We have your explicit consent. |
| To communicate with you and resolve any complaints that you might have.
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· It is necessary to enter into or perform your service agreement.
· We have a valid business reason (to communicate with you, record and investigate complaints and ensure that complaints are handled appropriately). · We need to use your information in order to comply with our legal and regulatory obligations.
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· You have given us your explicit consent
· We need to use your information in order to establish, exercise or defend legal rights.
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| To provide improved quality, training and security (for example, through recorded or monitored phone calls to our contact numbers, or carrying out customer satisfaction surveys). | · We have a valid business reason (to develop and improve the products we offer).
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· You have given us your explicit consent.
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| For business purposes and activities including maintaining business records, file keeping, strategic business planning and internal audit, and management information. | · We have a valid business reason (to run our business efficiently and effectively) | · You have given us your explicit consent.
· We need to use your information in order to establish, exercise or defend legal rights. |
| To apply for and claim on our own insurance.
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· We have a valid business reason (to maintain appropriate insurance) | · We need to use your information in order to establish, exercise or defend legal rights. |
| To provide marketing information where you have provided your consent
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· You have given us your explicit consent.
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- Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
- Selected third parties in connection with any sale, transfer or disposal of our business.
- Our insurers.
- Data protection authorities.
- Financial crime and fraud detection agencies.
- The police, HMRC and other crime prevention and detection agencies.
- Third parties who have entered into contractual arrangements with us to provide services we need to carry out our everyday business activities such as support specialists, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.
- Our Group Parent.
This section will apply where a client receiving services or wishing to receive services provides information about their family member(s) or business associates to explain their lifestyle and approach to investments and wealth management (for example if you are a spouse or dependant mentioned in a will or trust document or a business partner). This section will set out how we use your information.
- Information collected from the client;
- Information collected when dealing with any complaints you may have;
- Information collected from any communications with you; and
- Information obtained through audits or in the process of ensuring our Investment Managers or advisers comply with their regulatory obligations.
This will include:
- General information such as your name, address, phone numbers and email addresses, date of birth and gender.
- Your relationship to our client who is receiving services.
- Financial information relating to your financial liabilities, for example details of you and your partner’s property portfolio to enable us to provide appropriate advice to our client.
- We may collect details about your health which are relevant to the services our client receives (for example where you are the client’s partner and you have a medical condition which means that you are unable to work and therefore our client has a higher need for investment return and a lower risk appetite).
- you contact us by email, telephone and through other written and verbal communications, for example in relation to a data subject access request.
We will rely on the following “lawful basis” when we process your “personal information”:
- We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you.
- We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to maintain our business records.
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basis in these circumstances:
- We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.
- There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.
- It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
| Purpose for processing | Lawful basis for using your personal information | Lawful basis for using your special categories of personal information |
| To comply with our legal or regulatory obligations, including ensuring that our Investment Managers or advisers are compliant with the appropriate regulatory requirements. | · We need to use your information in order to comply with our legal obligations.
· We have a valid business reason (to run our business efficiently and effectively).
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· We need to use your information in order to establish, exercise or defend legal rights.
· We have a substantial public interest to prevent or detect unlawful acts (where we suspect fraud). · It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. · We have your explicit consent.
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| For communications purposes including handling complaints and dealing with any other communications. | · We have a valid business reason (to run our business efficiently and effectively). | · You have given us your explicit consent.
· We need to use your information in order to establish, exercise or defend legal rights. |
| For business purposes and activities including managing Rowan Dartington’s systems and ensuring the continued improvement our services. | · We have a valid business reason (to run our business efficiently and effectively).
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· You have given us your explicit consent.
· We need to use your information in order to establish, exercise or defend legal rights. |
- Third parties who facilitate the arrangement of products services we recommend such as Intermediary Independent Financial Advisors or the service/product provider themselves. Where we have shared your personal information with these third parties, they will also be a data controller and responsible for how they use your personal information. Their uses of your personal information will be governed by their own fair processing notices.
- Other Liberate Wealth group companies.
- Compliance consultants including the Consulting Consortium
- Financial crime and fraud detection agencies.
- Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
- Selected third parties in connection with any sale, transfer or disposal of our business.
- Our insurers.
- The police, HMRC and other crime prevention and detection agencies.
- Third parties who have entered into contractual arrangements with us to provide services we need to carry out our everyday business activities such as partner support specialists, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.
- General information submitted via the website, for example where you provide your details in the contact section such as your name, contact details and company name.
- Information such as IP address and browsing history obtained through our use of cookies. You can find more information about this in our cookies policy which can be found below.
We will rely on the following “lawful basis” when we process your “personal information”:
- We have a valid business reason to use your personal information, necessary for our everyday business operations and activities, for example to maintain business records and to monitor usage of the website.
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
| Purpose for processing | Lawful basis for using your personal information | Lawful basis for using your special categories of personal information |
| To respond to any enquiries you have submitted. | · We have a business reason (to respond to your enquires). |
- Other Liberate Wealth group companies;
- Third parties who we have entered into contractual arrangements to provide services we need to carry out our everyday business activities such as IT suppliers and website providers.
3. What marketing activities do we carry out?
We may use your personal information to provide you with information about our services or which may be of interest to you where you are an existing client. Where these are part of the ongoing services we offer or if you have provided your consent for us to do so.
We are committed to only sending you marketing communications you have clearly expressed an interest in receiving. If you wish to opt out of marketing, you may do so by clicking on the “unsubscribe” link that appears in all emails or telling us when we call you. Otherwise you can always contact us using the details set out in the contacting us section to update your contact preferences.
Please note that, even if you opt out of receiving marketing messages, we may still send you communications which are relevant to the nature of the products or the services we offer you, or which we are obliged to legally send to you.
4. How long do we keep personal information for?
We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out in section 3 above and to comply with our legal and regulatory obligations. As a financial service firm, we are regulated by the Financial Conduct Authority (the FCA) who impose certain record-keeping rules which we must adhere to for example:
- if we have any documents relating to a pension transfer you have made, the FCA require us to keep these documents and your related personal information indefinitely. However we will keep such documents for a period of 120 years to ensure that it covers your lifetime;
If you would like further information regarding the periods for which your personal information will be stored, please contact us using the details set out in the contacting us section.
5. What is our approach to sending your personal information overseas
There may be some instances where your personal information is transferred to countries outside of the European Economic Area (“EEA”) such as when we transfer information to our other companies in the Liberate Wealth group or to third party suppliers who are based outside the EEA or when third parties who act on our behalf transfer your personal information to countries outside the EEA. Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including:
- entering into data transfer contracts and using specific contractual provisions that has been approved by European data protection authorities otherwise known as the “standard contractual clauses”;
- transferring personal information only to companies in the United States who are certified under the “Privacy Shield”. The Privacy Shield is a scheme whereby companies certify that they provide an adequate level of data protection. You can find out more about the Privacy Shield https://www.privacyshield.gov/welcome; or
- we will only transfer personal information to companies in non-EEA countries who have been deemed by European data protection authorities to have adequate levels of data protection for the protection of personal information. You can find out more about this https://ico.org.uk.
We are also entitled under European data protection laws to transfer your personal information to countries outside the EEA where it is necessary for the performance of the contract we have with you. If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in section 11.
6. Your rights
You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in the ways set out in this notice. Please contact us at any time using the details set out in the contacting us section if you wish to exercise these rights; we will not usually charge you.
We respect your rights and will always consider and assess them but please be aware there may be some instances where we cannot comply with a request you make as the consequence might be:
- in doing so we could not comply with our own legal or regulatory requirements for example we are under obligations to hold records of our dealings with you for certain periods of time; or
- in doing so we could not provide services to you and would have to cancel your client agreement, for example we could not enter into investments on your behalf, or provide suitability advice if we had deleted your personal information.
We will of course inform you if any of the above situations arise and if we are unable to comply with your request.
We are happy to provide you with such details but in the interests of confidentiality, we follow strict disclosure procedures which may mean that we will require proof of identify from you prior to disclosing such information.
We will usually provide your personal information to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible.
If you would like to request a copy of the information we hold, please do so in writing to:
Information Security Officer
Compliance & Risk
Liberate Wealth
41 & 43 Maddox Street
Mayfair
London
W1S 2PD
Please help us to keep your personal information accurate and up to date so if you believe there are any inaccuracies, discrepancies or gaps in the information we hold about you, please contact us and ask us to update or amend it.
In certain circumstances, you have the right to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information.
Where we rely on your consent to process your personal information, you have the right to withdraw such consent to further use of your personal information.
You are entitled to request your personal information to be deleted in certain circumstances such as where we no longer need your personal information for the purpose we originally collected it. When you exercise this right, we need to consider other factors such as our own regulatory obligation, to assess whether we can comply with your request.
You have a choice about whether or not you wish to receive marketing information from us and you have the right to request that we stop sending you marketing messages at any time. You can do this either by clicking on the “unsubscribe” button in any email that we send to you or by contacting us using the details set out in the contacting us section.
Please note that, even if you opt out of receiving marketing messages, we may still send you communications which are relevant to the nature of services we offer you.
In certain circumstances, you can request that we transfer personal information that you have provided to us to a third party.
When you exercise this right, we need to consider other factors such as our own regulatory obligations, to assess whether we can comply with your request
Liberate Wealth does not rely on automated decision making to provide services or product recommendations to you.
If you believe we have breached data protection laws when using your personal information, you have a right to complain to the Information Commissioner’s Office (ICO).
You can visit the ICO’s website at https://ico.org.uk/ for more information. Please note that lodging a complaint will not affect any other legal rights or remedies that you have.
7. Contacting Us
If you would like any further information about any of the matters in this notice or if you have any other questions about how we collect, store or use your personal information, you may contact our Information Security Officer at Liberate Wealth, 41 & 43 Maddox Street, Mayfair, London, W1s 2PD, compliance@liberatewealth.co.uk.
8. Cookies
A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a website’s computer and stored on your computer’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a web site to access the cookies it has already sent to you, not the cookies sent to you by other sites.
Many sites do this whenever a user visits their website in order to track online traffic flows. Cookies record information about your online preferences. Users have the opportunity to set their computers to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these, of course, means that certain personalised services cannot then be provided to that user and accordingly you may not be able to take full advantage of all of the bbc.co.uk features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
If you have set your computer to reject cookies you can still browse www.staffordhouseinvestments.co.uk anonymously until such time as you wish to register for www.staffordhouseinvestments.co.uk services. For further information on cookies you may like to visit www.aboutcookies.org.
9. How do we protect your information?
At Liberate Wealth 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.
- We educate and train our employees and contractors on their information security, fraud prevention and privacy obligations annually.
- We continually review our physical and logical security controls in place across the business.
- We conduct security testing of our applications and services in a controlled testing environment before they are made available for our Clients to use.
- We have a business resiliency plan with disaster recovery and business continuity testing.
However, whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us.
10. Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the 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 addition, we use Google’s remarketing technology to advertise online. In doing so, Google will place or read a unique ad-serving cookie on your computer and will use non-personal information about your browser and your activity on our sites to serve ads on their content network. Please click here for more information about remarketing or to opt-out of the Google remarketing cookie.
We will only collect personal information about you if you send us an e-mail enquiry via the ‘contact us’ facility. In order for this to happen, you will need to fill out the on line ‘contact us’ form or complete the registration details. The type of information being collected for an enquiry will be apparent from the layout of the ‘contact us’ form. The information collected when you use this form, will be used for contacting you in relation to your query only.
We take all reasonable precautions to protect our visitors’ information, both on and off line. If your personal information changes, please let us know and we will correct, update or remove any information that we hold about you on our active databases. We may however need to retain archive copies of that personal information for legal or audit purposes. If you have any queries regarding the way in which Liberate Wealth or any of its subsidiaries handle data collected from you on this website, please contact us on 020 7184 9700.
By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out in the above four paragraphs.
11. Monitoring
Please note that if you communicate with us electronically, including by e-mail, telephone or fax, this communication may be recorded to protect the interests of our business and our clients. This includes for the purposes of maintaining client/service quality standards, detection of and/or prevention of crime and to ensure that Liberate Wealth employees comply with legal obligations and Liberate Wealth policies and procedures.
12. Hyperlinks
We may provide hyperlinks from this web site (‘the Site’) to web sites of other organisations including websites of associated companies. Please note that this Privacy Policy applies only to this Site and that Liberate Wealth will not liable for the contents of linked web sites or any transactions carried out with organisations operating those web sites.
13. Updates to this notice
From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments. We will provide you with the most up-to-date notice and you can check our website periodically to view it.
This notice was last updated on 25th May 2018.