Introduction
Balance: Wealth Planning Limited and Balance: Trustees Limited (which will together be referred to as ‘Balance’, ‘we’ or ‘us’) are committed to protecting and respecting your privacy.
We want you to feel comfortable about why we hold data about you, how we use it and keep it secure.
This privacy policy explains how and why we obtain, store and process personal information we collect about you through our communications with each other, including through www.balancewealth.uk (referred to as our ‘Website’).
Information we may collect about you
We collect information about you if you engage us for financial planning advice, or start the process of doing so. This information will relate to your personal and financial circumstances.
Some personal data we hold is particularly sensitive in nature and therefore requires more protection. That includes information about your health, your religion and sexual orientation, all of which are relevant when it comes to providing a holistic financial planning service to you.
Because this information is sensitive, we need your explicit consent to keep and use this data about you. We are confident that any sensitive information we hold will have been freely provided by you to enable us to act for you, or put together a proposal to do so. As a result, we have taken this as your explicit consent to store your data. We may also ask you to explicitly confirm you are happy for us to hold this data at a later date.
If you would like to withdraw that consent you can do so by getting in touch with us, and we will retain only that data that is essential for regulatory or other legitimate reasons.
We may also collect information when you voluntarily complete client surveys or provide feedback to us, or if you subscribe to receive news updates on our website.
Information about connected individuals
If you are a client of ours, or have expressed an interested in becoming a client, we may need to gather personal information about your close family members and dependants. We will do this in order to provide our service to you effectively, or to help us refine any proposal to provide services to you. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. You should provide a copy of this privacy notice to them.
Why we collect information about you
If you are a client of ours, or have expressed an interest in becoming a client, the primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you, whether that is already in place, or being proposed. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data, we would also be unable to fulfil our legal and regulatory obligations.
We usually also need to gather special category, or sensitive, personal data in order to fulfil our contract with you. We will obtain your explicit consent to collect and process this information.
We may also collect information about you so that we can send you news that we believe is relevant to you and your financial planning. That might include regulatory changes, reminders about key dates and tax allowances, planning ideas and details of changes to our team. This usually takes the form of a monthly email and is not a platform for promoting our services. We may also send birthday or Christmas cards.
You can choose whether you would like to receive these communications or not. You may update your preferences at any time by clicking the unsubscribe link on news emails, or by contacting us using the details at the end of this policy.
How will we use the information about you?
If you are a client of ours, or have expressed an interest in becoming a client, we collect information about you in order to provide you with the services within our contract, or tailor the proposed services we may provide.
For example, if you send us an email message requesting information about us, we will use your email address and other information you supply to respond to your request.
If you send us a CV to apply for a position with us, we will use the information provided to match you with available opportunities.
Who we might share your information with
If you are a client of ours, or have expressed an interest in becoming a client, in order to deliver our services to you effectively we may share your details with third parties. For example, that includes those businesses that we engage for professional compliance, accountancy or legal services. It also includes product and platform providers that we use to arrange financial products for you, and third parties who provide specific financial software, or business management tools, for example.
Where third parties are involved in processing your data we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with written instructions from you or us as appropriate.
In certain circumstances we may need to disclose information about you if required to do so by law. For example, we may need to comply with a court order, to take action for the purposes of preventing or reporting fraud or other crime, to apply the terms of our agreements with you, or to protect the rights or safety of our clients and employees.
To fulfil our obligations in respect of prevention of money-laundering, fraud, and other financial crime we may send your details to third party agencies for identity verification purposes. We will ask you for your consent to do that.
Rest assured, we only share your data to the extent it is necessary to carry out our services and to comply with regulations. We will never share, sell or rent your personal information to others for marketing purposes.
How long we keep your information
If you engage with us as a client, or we enter into discussions with a view to you becoming a client at a later date, we will retain all the personal data about you which is necessary to provide our services to you, or to aid us in tailoring the services we are proposing. We will take all reasonable steps to keep your personal data up to date throughout our relationship.
In principle, your personal data should not be held for longer than is required under the terms of our contract for services with you, whether that is in place or being proposed. However, we are subject to regulatory requirements to retain data for specified minimum periods. In some cases, we are required to keep relevant data indefinitely.
We reserve the right to retain data relating to our relationship with you as a client (past, present or proposed) for longer than the minimum regulatory periods due to the possibility that it may be required to defend a future claim against us. This stance is for your benefit as well as our own. With that in mind, we will not retain your personal data for longer than 5 years after being aware of your death.
You have the right to request deletion of your personal data. We will comply with this request so far as we are able to, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
If you are not a client, have never been, and we are not proposing providing services to you, we will only hold the data about you for as long as necessary to fulfil the purposes for which we collected that information, or as required by law.
If you applied for an employment position with us, and were unsuccessful, we will retain your details for three years on the basis that we may consider employing you again in the future and to protect both of us against any future employment law claim.
How we keep your information secure
Keeping information about you secure is very important to us. We have technological and operational security policies and procedures in place to protect your personally identifiable information from loss, misuse, alteration or unintentional destruction. Our team, and the third parties we work with, have been trained to maintain the confidentiality of such information.
Electronic data, including certain sections of our website site generally have encrypted data using SSL or a comparable standard. However, no data transmission over the internet can be guaranteed to be totally secure.
Hard data provided in paper form is only retained where necessary and is kept in locked cabinets.
We take reasonable steps to ensure that other companies with whom we must share your data from time to time operate within the data protection regulations.
While we strive to protect your personal information, we cannot ensure or warrant the security of any information which you send to us, and you do so at your own risk.
Accessing and updating your personal information
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some, or all, of your personal information, please email or write to us using the contact details noted below.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
Children
We understand the importance of protecting children’s privacy, especially in an online environment. Our services and website are not intentionally designed for or directed at children. It is our policy never to knowingly collect or maintain information about children other than where that information is provided by their parents or guardians and it is required in order to fulfil our contract to provide services.
Automated decision making and profiling
If we use any system which is designed to make automated decisions or profiling, your personal information will be gathered through the information that you input onto the system. Your data is collected in order for us to carry out the service for which you engage us. If you’re unsure about the outcome of the automated process you can contact us to discuss or to challenge the outcome.
We take measures to ensure the security of your data. We don’t use any special category data (such as data about your health) in an automated process unless it’s strictly necessary to deliver our service and we have obtained your explicit consent to do so.
We will regularly check our systems for accuracy and bias and feed any changes back into the design process.
Marketing
We may like to occasionally send communications which promote our services.
We will only send you such communications if you have explicitly indicated to us that you want to receive them. This does not include newsletters and updates which are provided to our clients and those people considering working with us, as part of our contract with them.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us using the details below.
Our Website
When you use our Website and make use of any services we offer via our Website, you are agreeing to the terms of this policy insofar as it relates to the information we may collect about you through our Website.
Please note that this privacy policy does not apply to other websites linked through our Website. Personal information which you choose to provide to other websites will be subject to the privacy policies of those websites.
We may collect information about you when you use our website, including storing your IP address and by using cookies. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. The type of information depends on how you use our website. If you visit our site to read or download information, such as guides, or articles, none of the information we collect is personally identifiable.
Information about how you, and others, use our website will only be used for statistical purposes (in aggregate form) to make it more useful and attractive to you.
We use Google Analytics and cookies to track visitor use of the website and to compile statistical reports on website activity. For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
Location of your data
As part of the services offered to you, the information you provide to us may be transferred to countries outside of the European Union (‘EU’). For example, this may happen if any of our servers are from time to time located in a country outside of the EU or one of our service providers is in a country outside of the EU. These countries may not have the same data protection laws to the UK. If we transfer your information outside of the EU in this way, we will take steps to ensuring that your rights continue to be protected as outlined in this privacy policy.
Your rights
You have the following rights so far as your data is concerned, which we respect and comply with, although in some cases our regulatory obligations can supersede these rights:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
For full information, please refer to the Information Commissioner’s website: www.ico.org.uk
Complaints
Companies that have any access to data are called Data Controllers in law. We are Data Controllers and we are registered with the Information Commissioner in the UK under references ZA022989 (Balance: Wealth Planning Limited) and ZA215712 (Balance: Trustees Limited). Further details of the registration are available at ico.org.uk
You have a right to lodge a complaint with the supervisory authority for data protection.
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Phone 0303 123 1113
Changes to our privacy policy
We keep our privacy policy under regular review and we will show the most recent policy on our website www.balancewealth.uk/privacy-policy. This privacy policy was last updated on 22nd May 2018.
How to contact us
If you have any questions or complaints relating to this Privacy Policy or how we use the personal information we have about you, please contact our Managing Director, Rebecca Aldridge, using the details below.
team@balancewealth.uk | 0800 7723456 | The Point, Loughborough Road, West Bridgford, Nottingham NG2 7QW