Policies – Wild & Company

DATA PRIVACY NOTICE

We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are

Wild & Company Limited collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws. When we mention "Wild & Company, "we", "us" or "our" we are referring to Wild & Company Limited.

Wild & Company is a company registered in England and Wales company no 314606, whose registered office is at Tudor House, Royal Court, Macclesfield, Cheshire SK11 7AE. Wild & Company Limited is authorised and regulated by the Financial Conduct Authority. Wild & Company Limited Financial Services Register number is 179387. We provide you with intermediary investment advice services including advising and arranging deals in investments and non-investment insurance contracts.

The personal data we collect and use

In the course of providing our service to you we may collect the following personal data when you provide it to us. We will collect and record your personal data from a variety of sources and directly from you during the course of our initial meetings and conversations with you. You may provide the information verbally, in writing and by email. Your personal data may include:

Personal/contact information: names, nationality, gender, civil/marital status, date of birth, address, email, landline, mobile numbers.
Identity information: Passport information, driving licence, National insurance number, nationality and residency
Financial information: Bank account details, existing insurance/investment/pension details, assets, liabilities, mortgage, loans and credit, tax status, income / expenditure
Employment details: renumeration/ employment status, company information, sick pay/other employer benefits
Lifestyle information: smoker status, alcohol consumption, health, retirement age
Health information: medical details and history
Details of any vulnerability
Family/associated people: Details of your family, spouse/partner, next of kin, dependents and/or beneficiaries under a policy or a where we provide our services to trusts, information about the settlor and trustees

Where we provide services to companies we may collect company information such as personal information for Directors, Shareholders and beneficial owners.

If you are providing information about another person or company details we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us in one of the ways described below.

Information we generate about you

Information included in client documentation records, products and services you hold, records of correspondence and other communications between us, such as telephone calls and email correspondence along with information to support our regulatory requirements.

Information collected from other sources

We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.

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

Policy details from product providers or another agent.
Financial/personal information from another professional adviser e.g. solicitor/accountant or from a Power of Attorney.
Information from external third parties to verify your identity and sanctions check information.
Financial information from governmental institutions.
Financial Information from an employer.

How we use your personal information

To perform our contract with you and to support and maintain that relationship, this includes:

Assessing and processing an application and completing any transactions
To regularly communicate with you
Providing our services to you including the management of our relationship with you and the product provider, including sending out
Monitoring telephone calls with you to take your instructions, resolve any queries or issues
Record keeping to ensure our services operate within the law and relevant regulatory requirements

For legitimate interest purposes, this includes:

To provide you with information about other services similar to those that you already have enquired about
Providing communications which we think will be of relevance to you.

To comply with legal and regulatory requirements, this includes:

Confirming your identity for regulatory purposes
Verifying your identity for security purposes
Detecting and preventing fraud, money laundering, terrorist financing, bribery or other malpractice
Maintaining effective management systems, accounting records, internal audit requirements and receiving professional advice including reporting to our regulator in compliance with any legal and regulatory obligation.
To resolve any complaints you may have
To evidence satisfaction of any request made by you in accordance with your rights under data protection regulation

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’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is 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 or in the context of investment/pension product. In addition to the lawful basis for processing this information set out in the above, we will be processing it either (i) for the purpose of advising on, arranging or administering an insurance/investment/pension contract or (ii) for the establishment, exercise or defence of legal claims.

In the course of our activities relating to the prevention, detection and investigation of financial crime, we may process criminal conviction or offence information. Where we do so, in addition to the lawful basis for processing this information set out in the above, we will be processing it for the purpose of compliance with regulatory requirements relating to unlawful acts and dishonesty.

Who we share your information with and why

We share your information with trusted third parties, who perform tasks for us and help us to provide our services to you and with other agencies where required by law, court order or regulation. Some of these third-party recipients may be based outside the European Economic Area – for further information including on how we safeguard your personal data when this occurs (see Transfer of your information out of the EEA below). These include:

Investment or product providers: Insurance/investment companies, Platforms, Trustees who ask for that information in order to allow us to make investments or arrange insurance contracts on your behalf or to continue to provide our services to you.
Third parties who help us provide maintenance and effective security of our office database and software programmes where your data is held.
Third parties that we engage for professional compliance, legal or accountancy services.
Your advisers, for example your accountant, tax adviser, solicitor.
Organisations including the police and fraud prevention agencies to prevent and detect fraud.
Regulatory or governmental agencies such as the Financial Conduct Authority.
A prospective buyer or its advisor for due diligence purposes, if we are considering a sale or restructuring of our business.
A third-party Credit Reference Agency to verify your identity or the identity of individuals and company directors and the beneficial owners of organisations, companies and trusts in line with money laundering or other requirements. To do so the Credit Reference Agencies may check details you supply against any particulars on any database (public or otherwise) to which they have access. They may also use your details in the future to assist other companies for verification purposes. A record of the search will be retained. The Credit Rating Agency holds personal data under their own data retention policy and in line with anti-money laundering 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 will only do so where we have a legitimate business reason to do this and will do so in accordance with any marketing preferences you have provided to us.

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

By phone: 01625 627 627
By email: advice@wildandcompany.ltd.uk
By Post: Tudor House, Royal Court, Macclesfield, Cheshire SK11 7AE.

Whether information has to be provided by you, and if so why

We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with intermediary services.

How long your personal data will be kept

We keep your personal information only as long as is necessary for the purpose for which it is collected, or for legal regulatory reasons. When deciding how long to keep your personal information after our relationship has ended, we take into account our legal obligations and regulators expectations. We may also retain records to investigate or defend potential legal claims. Personal information will be securely disposed of when it is no longer required in accordance with our data privacy policy.

Transfer of your information out of the EEA

We may transfer your personal data to the following which are located outside the European Economic Area (EEA) as follows:

Suppliers and sub-contractors which provide services to us.

If we do transfer your personal data to our suppliers and sub-contractors outside of the EEA, we will make sure that it is protected in a similar way as if it was being used in the EEA. We will use one of these safeguards:

The transfer will be to a non-EEA country with privacy laws that give the same protection as the EEA.
The transfer will be subject to a European Commission approved contract designed to help safeguard your privacy rights and give remedies in the unlikely event of a misuse of your personal data.
The transfer will be 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 and it makes sure those standards are similar to standards used within the EEA.
The transfer will be subject to binding corporate rules (agreements governing transfers made between organisations within in a corporate group).

You have a right to ask us for more information about the safeguards we have put in place as mentioned above. To learn more, please see ‘Your rights’ below.

Your rights

You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:

To access personal data
To correct/erase personal data
To restrict how we use personal data
To object to how we use personal data
To ask us to transfer personal data to another organisation
To object to automated decisions
To understand how we protect information transferred outside Europe
To find out more about how we use personal data

We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.

We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request.

We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests. We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.

To access personal data

You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.

To rectify/erase personal data

You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.

You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.

You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information if we originally asked for your consent to use your information or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.

We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.

To restrict our use of personal data

You can ask that we restrict our use of your personal data in certain circumstances, for example:

where you think the information is inaccurate and we need to verify it;
where our use of your personal data is not lawful, but you do not want us to erase it;
where the information is no longer required for the purpose for which it was collected but we need it to establish, exercise or defend legal claims; or
where you have objected to our use of your personal data, but we still need to verify if we have overriding grounds to use it.

We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.

To object to use of personal data

You can object to any use of your personal data which we have justified on the basis of our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.

To request a transfer of personal data

You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).

You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.

To obtain a copy of our safety measures for transfers outside of Europe

You can ask for a copy of, or reference to, the safeguards we have put in place when your personal data is transferred outside of the European Economic Area. We are not required to share details of these safeguards where sharing such details would affect our commercial position or create a security risk.

You can contact us for more information

If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data.

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

Email or write to us at advice@wildandcompany.ltd.uk or by post Tudor House, Royal Court, Macclesfield, Cheshire SK11 7AE

let us have enough information to identify you, e.g. name, address, date of birth;
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know the information to which your request relates.

Keeping your personal data secure

We will record and store your data in our paper files and on our computer systems. We have appropriate security measures in place 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 who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Our supervisory authority

If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).

We ask that you please attempt to resolve any issues with us before the ICO.

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you. Please send an email to advice@wildandcompany.ltd.uk or write to Wild & Company Limited, Tudor House, Royal Court, Macclesfield, Cheshire SK11 7AE or phone 01625 627627

Issue date 25/05/2018 v1