Kingswood Investment Management Limited (Ref ZA021654)
Kingswood Wealth Planning Limited (Ref ZA021657)
Kingswood Group Limited (Ref Z2392129)
This Policy may be subject to change in the future.
WHAT IS PERSONAL INFORMATION
When we refer to personal information we mean information about an individual that can identify them, such as name, address, email address, and telephone number. It can also include information such as your financial circumstances, your bank details and records of communications, e.g. letters, e-mails and recorded telephone conversations. Any reference to information or data in this Policy is in reference to any personal information about a living individual.
Sensitive data is information related to any of the following: health, racial or ethnic origin, political opinions, religious or philosophical beliefs, and data regarding sexuality.
INFORMATION WE COLLECT
The information that we collect and store relating to you is primarily used to enable us to provide our services to you. Without it we may not be able to do so. We’ll process your personal information to carry out our responsibilities resulting from any agreements you’ve entered into with us and to provide you with information, products and services. We may use information to develop and test the effectiveness of marketing activities and to improve our services. In addition, we may use it to provide you with marketing information about services and products we offer which may be of interest to you and to notify you about changes to our services and products. We may deliver this information by post, email, telephone or otherwise including social media platforms. We may also use your name and address to post to you invitations to events. You have the right to request us not to process your information for marketing purposes at any time by contacting us. If you no longer wish to be contacted for marketing purposes please email us at GDPR@kw-wealth.com or write to us using the information at the end of this notice.
We process your personal data pursuant to the following legal bases:
· To comply with our legal and regulatory obligations;
· Performance of a contract;
· To establish, exercise or defend our legal rights and/or for the purpose of (or in connection with) legal proceedings;
The use of your personal data as described is necessary for our legitimate business interests which are:
· Enforcing the terms and conditions of any agreement we have with you;
· Assessing the suitability of any Wealth planning or investment decision made directly by you, or by us, on your behalf;
· Improving customer service, market research, quality assurance, and training staff.
STORING YOUR PERSONAL DATA AND TIMEFRAME
Any personal information that we do obtain from you will be handled in accordance with data protection law. We’ll determine the length of time we keep it based on the minimum retention periods required by law or regulation. We will only keep your personal information after this period if there is a legitimate reason to do so.
SHARING YOUR INFORMATION
We will only disclose your information to associated companies within the Kingswood Group. We may transfer information outside of the EEA but before doing so will take reasonable steps to enter into a suitable agreement with the recipient of the information and/or adopt any necessary measures in order to ensure an adequate level of protection with respect to your privacy rights and protection of your personal information in each case in accordance with applicable legislation.
If you have been dealing with a financial adviser, we may provide information about your dealings with us to enable the adviser to give you informed advice. We may be under a duty to disclose or share your information in order to comply with any legal obligation or regulatory requirements. This includes sharing information with any relevant authority where we are obligated to do so including but not limited to regulators, government (e.g. HRMC) and law enforcement or fraud prevention agencies.
We may provide information to service providers to enable us to fulfil our relevant checks for anti-money laundering purposes. We may provide information to our appointed auditors and other professional advisers to the extent that they require such information to provide advice.
In the event we sell or buy any business or assets where we may also disclose your information to the prospective seller or buyer of such business or assets. Otherwise, we may share information in order to enforce or apply the terms of any contract with us.
You have rights under data protection law that relate to the way we process your personal data. More information can be found on the Information Commissioner’s website. Broadly:
You have the right to access the personal data we hold about you
You have the right to make us correct any inaccurate data we hold about you
The right (in certain circumstances) to make us erase any personal data we hold about you
The right (in certain circumstances) to restrict our processing of the personal data we hold about you.
The right to object to our processing of personal data we hold about you
The right to receive personal data you have provided to us in a portable format or otherwise
The right to withdraw your consent where we are relying on it to use your personal data (e.g. for marketing purposes)
Request a copy of the information we hold about you, to request rectification, erasure.
Should you wish to receive details that we hold about you please contact us at the email address below.
CONTACTS AND COMPLIANTS
If you have any questions about this Policy or wish to exercise any of your rights please get in touch with us either at GDPR@kw-wealth.com or by writing to the Data Protection Officer at the following address:
13 Austin Friars
We hope that you will never have reason to complain about the way we process your personal information or with the way we’ve handled a request by you in relation to your rights. However, if something does go wrong please bring it to our attention as soon as you can. We will try to resolve the matter fairly and quickly. Please contact us on the same details above. You also have the right to make a complaint to the Information Commissioner’s Office. Their address is:
Information Commissioner’s Office