Our Data Privacy Notice

Richmond Wealth LLP is dedicated to protecting your personal information.

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.

We may need to make changes to our General Data Protection Regulation and Privacy Policy Notice; so please check with us or go to our website [www.richmondwealth.co.uk] for occasional updates. If there are important changes such as changes to where your personal data will be processed; we will contact you directly.

This version of our General Data Protection Regulation and Privacy Policy Notice was last revised on 24 May 2018 and applies to Richmond Wealth LLP.

Who we are

We are Richmond Wealth LLP (“Richmond Wealth”) an Independent Financial Advice firm of Chartered Financial Planners.

Richmond Wealth LLP 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 “Richmond Wealth”, “we”, “us” or “our” we are referring to Richmond Wealth LLP.

We are a Limited Liability Partnership (LLP) in England and Wales (OC383403) [Richmond Wealth LLP] registered office is at 41 Lothbury, London, EC2R 7HG. Richmond Wealth LLP is authorised and regulated by the Financial Conduct Authority. Richmond Wealth LLP’s Financial Services Register number is 600308.

The personal data we collect and use

Information about you that we collect and use includes:

• Information about who you are e.g. your name, date of birth and contact details
• Information connected to your product or service with us e.g. your bank account details
• Information about your contact with us e.g. meetings, phone calls, emails / letters
• Information that is automatically collected e.g. via cookies when you visit one of our websites
• Information if you visit one of our offices e.g. visual images collected via closed circuit television (CCTV)
• Information classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil partnership status and finances. This information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations
• Information you may provide us about other people e.g. joint applicants or beneficiaries for products you have with us
• Information on children e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)
• If you are providing information about another person 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.

Where we collect your information

We may collect your personal information directly from you, from a variety of sources, including:

• an application form for a product or service
• phone conversations with us
• emails or letters you send to us
• meetings with one of our financial advisers [Richmond Wealth LLP]
• participating in customer satisfaction surveys to help us understand you better and improve our services
• our online services such as websites and social media accounts

If you have a financial adviser and / or are a member of your employer’s pension scheme, the information we collect and use will most likely have been provided by them on your behalf.

We may also collect personal information on you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.

What we collect and use your information for

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:

• you have given us your permission [consent] to send you information about products and services offered by other parts of Richmond Wealth LLP and / or selected third parties we have chosen to work with which we believe may be of interest and benefit to you
• it’s necessary to provide the product or service you have requested e.g. if you wish to invest in a third party pension or savings products, we will require some personal information including your name, address, date of birth, bank account details
• it’s necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Statements, tell you about changes to Terms and Conditions or for the detection and prevention of fraud
• it’s in the legitimate interests of Richmond Wealth LLP e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from your product or investment; where we need to process your information to better understand you and your needs so we can send you more relevant communications about the products you have with us and to develop new products and services; where we use artificial intelligence or computer algorithms to improve the products and services offered to you
• it’s in the legitimate interests of a third party e.g. sharing information with your employer’s adviser for the governance of a pension scheme of which you are a member

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.

We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect and use from others – about you. These automated decisions can affect the products, services or features we offer you now or in the future. We use automated decisions in the following ways:

• Tailoring products and services e.g. placing you in groups with similar customers to make decisions about the products and services we may offer you to help meet your needs
• When designing and enhancing our online services to help meet your requirements for ongoing guidance and support

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-

• From employers regarding workplace pensions;
• From lenders and/or product providers:
• For product information;
• From identification and verification checking agencies:
• For identity information
• For sanction check information.

How we use your personal data

The below table sets out:

• how we use your personal data
• the lawful bases upon which we collect and use your personal data
• who we routinely share your personal data with

Rationale/Reason for Processing	Lawful Basis for Processing	Third party recipients linked to that activity
·         To provide you with intermediary services	Performance of a contract	·         Workplace pension providers
·         To provide quotations for protection products ·         To apply for protection/investment products on your behalf	Performance of a contract	·         Product providers
·       To refer you to third party advisers to provide you with advice in relation to mortgage and/or legal advice	Consent	·         Local accountants, solicitors, mortgage brokers
·       To retain records of any services or advice provided to you by us in order to defend potential legal claims or complaints	Legitimate Interests	·         External supplier(s) of data storage and data hosting services to retain records on our behalf
·       To provide you with details of products and services from us and third parties that may be of interest to you in accordance with your preferences. For more information see ‘Marketing’ below	Consent	·         Not applicable

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 product; and/or
• criminal conviction or offence information when providing intermediary services in relation to a general insurance product
• In addition to the lawful basis for processing this information set out in the above table, we will be processing it either (i) for the purpose of advising on, arranging or administering an insurance 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 table, we will be processing it for the purpose of compliance with regulatory requirements relating to unlawful acts and dishonesty.

Who we may share your information with

We may share your information with third parties for the reasons outlined in ‘What we collect and use your information for.’

These third parties include:

• Your adviser or employer
• Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers e.g. research, consultancy or technology companies; or companies who can help us in our contact with you, for example an internet service provider
• Our regulators and Supervisory Authority e.g. the Financial Conduct Authority (FCA), the Information Commissioner’s Office for the UK (the ICO)
• Law enforcement, credit and identity check agencies for the prevention and detection of crime
• HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance

We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

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 obtained your consent and then or have a legitimate business reason to do this and will do so in accordance with any marketing preferences you have provided to us.

In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.

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

• By phone: 020 8133 2344
• By email: info@richmondwealth.co.uk
• By Post: Richmond Wealth LLP, 41 Lothbury, London, EC2R 7HG

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 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 will keep your personal information only where it is necessary to provide you with our products or services while you are a customer of Richmond Wealth and therefore until your client agreement has been terminated.

We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.

Transfer of your information out of the EEA

We will not transfer your personal data outside of the European Economic Area or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

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 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 purposes 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 contest decisions based on automatic decision making

If we made a decision about you based solely by automated means (i.e. with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted suitable safeguards in our decision making processes to protect your rights and freedoms.

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 Richmond Wealth LLP at info@richmondwealth.co.uk or 41 Lothbury, London, EC2R 7HG;
• 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 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.

Cookie Policy

A cookie is a small text file, which often includes a unique identifier that is sent by a web server to your computer, mobile phone or any other internet enabled device (“device”) when you visit a website. Cookies are saved onto your computer or other device when you visit our website.

Cookies store small pieces of information. For example – they will remember you’ve visited our website or performed a certain action.

Cookie Use

We use cookies to help us improve your experience when you visit our website. For example, a cookie might store information so you don’t have to keep entering it.

Cookies also let us know which pages of our website you visited; they help us develop and market our products and services.

We use three main types of cookies:

1. ‘Performance’ cookies
2. ‘Identification’ cookies
3. ‘Targeting’ cookies.
4. ‘Performance’ cookies are used to help us see how you use our Website e.g. which pages you visit. These cookies don’t collect any information that could identify you – all the information collected is anonymous and is only used to help us improve the performance of our Website, understand what interests our users and measure how effective our advertising is. We use performance cookies to analyse the performance of our Website, to help us improve the Website by measuring any errors that occur and to see how effective our adverts are (this isn’t shared with 3rd parties). Sometimes cookies are managed for us by third parties, but we don’t allow the third party to use the cookies for any purpose other than those listed above. By using our Website, you accept the use of ‘Performance’ cookies.
5. ‘Identification’ cookies are used to help us customize website content based upon your selections. We use identification cookies to remember choices you have made such as identifying yourself as an IFA or Adviser, to show you when you’re logged in to the website and to target you with adverts on other websites. You can control whether or not these cookies are used, but preventing them may mean you are unable to access certain features or services. Preventing these cookies may stop us remembering that you didn’t want a specific feature or service. By using our Website you accept the use of ‘Identification’ cookies.
6. ‘Targeting’ cookies are used to send you relevant information and see which content you use. We use targeting cookies to send you customised news content via email, to track which content you use and to target you with adverts on other websites. By using our Website you accept the use of ‘Targeting’ cookies. There are third parties that provide Richmond Wealth LLP with content and functions on our Website, some of these providers will use cookies to ensure the particular areas on the Website work.

Controlling Cookies

 

You have control over if you allow cookies to be used when on our website. If you do not want our website to store cookies on your computer or device then you should refuse when prompted upon visiting our webpage.

Some features may be affected if you do not allow cookies, if this happens you can contact us and we will provide the information or service to you.

 

You can use your web browser to:

• delete all cookies;
• block all cookies;
• allow all cookies;
• clear all cookies when you close the browser;
• block third-party cookies;
• open a ‘private browsing’ / ‘incognito’ session, which allows you to browse the internet without storing local data; and
• install add-ons and plug-ins to extend browser functionality.

Opting out of cookie use

At any point, you have the right to request that we do not process your personal information for any marketing purposes.

You can opt-out of the Google Display Advertising Features and customise Google Display Network ads using the Ad Settings. As an added privacy measure, you can also use the Google Analytics opt-out browser add-on. However, please note that if you do this you may not be able to use the full functionality of this Website.

To remove other cookies from your PC, you can use these guides:

• Internet Explorer: https://support.microsoft.com/en-us/kb/278835#/en-us/kb/278835
• Chrome­: https://support.google.com/chrome/answer/95647?hl=en
• Safari: https://support.apple.com/kb/PH17191?locale=en_GB
• Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

Additional Cookie information

• Cookie Directive: http://www.ico.gov.uk
• Information about cookies: http://www.allaboutcookies.org
• Internet Advertising Bureau: http://www.youronlinechoices.eu
• International Chamber of Commerce United Kingdom: http://www.iccwbo.uk/pages/privacy

 

Our Supervisory Authority

We will always strive to collect, use and safeguard your personal information in line with data protection laws including the Data Protection Act 119 and GDPR 2018. If you do not believe we have handled your information as set out in our Privacy Policy, please visit our Contact us page, and send us a message. In addition to this, you may contact us by phone on 020 81332344, email at info@richmondwealth.co.uk or by post to 41 Lothbury, London, EC2R 7HG. We will do our utmost to make things right.

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

If you have any questions about our Data Privacy Notice or the information we collect or use about you, please contact:

Richmond Wealth LLP
41 Lothbury
London
EC2R 7HG

Email: info@richmondwealth.co.uk

 

Registered Office:

Richmond Wealth LLP

41 Lothbury

London

EC2R 7HG

 

 

Glossary of Terms

We, us or our – Richmond Wealth LLP a Limited Liability Partnership incorporated under the Limited Liability Partnerships Act 2000 registered in England and Wales (OC383403) and having its registered office at 41 Lothbury, London, EC2R 7HG.

Contact information – these are details that can be used to contact a person, including title, first name, surname, personal telephone number, fax, email address, home address, country, postcode or city of residence. This may also include work contact information such as work telephone number, fax, work email and work address

Data controller – means a natural or legal person (such as a company) which determines the means and purposes of processing of personal data. For example, we are your data controller as we determine how we will collect personal data from you, the scope of data which will be collected, and the purposes for which it will be used in the course of us providing you with intermediary services

Data protection regulation – applicable data privacy and protection laws

Employment status – this is information about your work, if you are employed, self-employed, unemployed, a student or on job seeker allowance

FCA – the Financial Conduct Authority, being the independent watchdog that regulates financial services

Financial information – this is information relating to your financial status, including salary/income, outgoings/expenditure, tax rate and P60

Health information – this is information relating to your medical history, including symptoms, diagnoses, procedures and outcomes, as well as information about your height and weight. This could include previous and current or persistent medical conditions and family medical history

Identity information – this is any information that can be used to distinguish a person or verify their identity, such as name, date of birth, place of birth, gender, marital status, national identity card/number, passport, drivers licence and national insurance number

Intermediary services – these are the services we provide to you in relation to the products, which may include workplace pensions.

Lenders – a mortgage lender (for a list of current lenders which we work with, please contact us – see How to contact us above)

Lifestyle information – this includes both work and leisure behaviour patterns. Most relevant to your products may be your smoker status, alcohol consumption, health, retirement age and exercise habits

Product – this is an investment, pension, protection and/or general insurance product in respect of which we provide intermediary services to you

Product provider – a company which provides investment, pension, protection and/or general insurance products (for a list of product providers which we work with, please contact us – see How to contact us above)

Sanction check information – this is information relating to your politically exposed persons (PEPs) status and Her Majesty’s Treasury financial sanctions status, which is recorded to prevent fraud and money laundering

Vulnerability – a vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when an advisory firm is not acting with appropriate levels of care. These customers are more likely to suffer severe detriment if something goes wrong. Details of vulnerability fall in to the following categories: health; resilience (financial); life events; and capability (financial knowledge/ confidence)