Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
How do we collect information from you?
We may collect our personal information from a variety of sources, including:
- Information that we collect from you directly when you contact one of our local offices;
- Information that you provide by filling in the on-line enquiry form on our site www.coolebeviswm.com
- Information that we collect about you from other commercially available sources (such as credit reference agencies);
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.
What type of information do we collect from you?
The personal information we collect from you will vary depending on which services you engage us to deliver. The personal information we collect might include your name, address, telephone number, email address, your Unique Tax Reference (UTR) number, your National Insurance number, bank account details, your IP address, which pages you may have visited on our website and when you accessed them. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services. We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Information about connected individuals
How is your information used?
In general terms, and depending on which services you engage us to deliver, as part of providing our agreed services we may use your information to:
- contact you by post, email or telephone
- verify your identity where this is required
- understand your needs and how they may be met
- maintain our records in accordance with applicable legal and regulatory obligations
- process financial transactions to you or your employees, if you use our payroll service
- prevent and detect crime, fraud or corruption
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. 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’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
We are required by legislation, other regulatory requirements and our insurers to retain your data where we have ceased to act for you. The period of retention required varies with the applicable legislation but is typically six years. To ensure compliance with all such requirements it is the policy of the firm to retain all data for a period of seven years after our relationship with you has ended. In some cases, data will be retained for significantly longer periods for instance, where there is an ongoing trust or there has been a financial transaction such as an investment or disposal that may later need to be referred back to.
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
- Five years for investment business
- Indefinitely for pension transfers and opt-out business
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so. You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
Who has access to your information?
- We will not sell or rent your information to third parties.
- Any staff with access to your information have a duty of confidentiality under the ethical standards that this firm is required to follow.
- If you agree, we may email you about other products or services that we think may be of interest to you.
- We won’t share your information for marketing purposes with companies outside our group of companies / other companies.
- In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
- Where third parties are involved in processing your data we’ll 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 our written instructions.
- Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit. We will as a minimum encrypt any documents sent electronically with a password or pass code.
- To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
Third Party Service Providers working on our behalf
We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf, for example to process payroll, compliance consultants or basic bookkeeping. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes. Third parties may be in the EU or elsewhere in the world but in each case, the duty of confidentiality incumbent upon them will be the same.
Personal Finance Portal (PFP) – online banking
|Categories of personal data||All personal data processed through the PFP, as well as information collected from payment service providers.|
|Purposes of processing||For the provision of the PFP open banking service, which is an account information service. An account information service is an online service which provides consolidated information on payment accounts held by a client with payment service providers (such as banks).|
|Recipients of personal data||Intelliflo Limited and its service providers.|
|Transfers of personal data outside of the EU||None|
|Automated decision making||The PFP open banking service does not utilise personal data to make automated decisions.|
Automated decision making and profiling
If you use our Insignis Cash Management Service via our website link 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 the outcome.
We take measures to ensure the security of your data and the link, which is provided, when an account has been set up used 2 Factor Authentication using an agreed pin number only known to you. We do not use any special category data (such as data about your health) in the automated process unless it’s strictly necessary to deliver our service and we have obtained your explicit consent to do so. We regularly check our systems for accuracy and bias and feed any changes back into the design process. Where your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
How you can access and update your information
Keeping your information up to date and accurate is important to us. We commit to regularly review and correct where necessary, the information that we hold about you. If any of your information changes, please email or write to us, or call us using the ‘Contact information’ noted below.
You have the right to ask for a copy of the information which Coole Bevis Wealth Management holds about you.
Our site contains links to third party websites and social media (such as LinkedIn and Twitter). If you follow a link to any of these sites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Communicating service related information: We may occasionally contact you by post, email or telephone with details of any changes in legal and regulatory requirements or other developments that may be relevant to your affairs and, where applicable, how we may assist you further. If you do not wish to receive such information from us, please let us know by contacting us as indicated under ‘Contact information’ below. If you’ve agreed to receive marketing information, you may opt out at a later date.
General and sector specific newsletters: We offer a monthly e-newsletter and other sector and service specific newsletters. At the outset we will seek your permission to subscribe you this service. You can subsequently unsubscribe at any time from within such newsletters or emailing email@example.com.
Access to your information: You have the right to request a copy of the personal information about you that we hold.
Correcting your information: We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
Deletion of your information: You have the right to ask us to delete personal information about you where:
- you consider that we no longer require the information for the purposes for which it was obtained;
- you have validly objected to our use of your personal information (see ‘Objecting to how we may use your information’ below);
- our use of your personal information is contrary to law or our other legal obligations;
- we are using your information with your consent and you have withdrawn your consent ( see ‘Withdrawing consent to use your information’ below).
Restricting how we may use your information: In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where there is no longer a basis for using your personal information but you do not want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
Objecting to how we may use your information: Where we use your personal information to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.
Withdrawing consent to use your information: Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given. You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.
Please contact us in any of the ways set out in ‘Contact information’ below if you wish to exercise any of these rights.
For more information on GDPR and your rights please see:
Changes to our privacy notice
The Compliance Manager, Coole Bevis Wealth Managment, Amelia House, Crescent Road, Worthing BN11 1RL.
We seek to resolve directly all complaints about how we handle your personal information, but you also have the right to lodge a complaint with the Information Commissioner’s Office.
Information Commissioner’s Office
Telephone: 0303 123 1113 (local rate) or 01625 545 745
Appendix 1 – Protecting your personal information
To provide our services properly we will need to collect information about your personal and financial circumstances. We take your privacy seriously and will only use your personal information to deliver our services.
Processing of your personal data is necessary for the performance of our contract for services with you and in meeting our obligations to prevent money laundering or terrorist financing. Generally this is the lawful basis on which we intend to rely for the processing of your data. (Please see the reference to special categories of data below). Our policy is to gather and process only that personal data which is necessary for us to conduct our services appropriately with you and to prevent money laundering or terrorist financing.
We adopt a transparent approach to the processing of your personal data. Sometimes, we may need to pass your personal information to other organisations. If you apply to take out a financial product or service we will need to pass certain personal details to the product or service provider.
We may engage the services of third party providers of professional services such as an introduction to a mortgage broker in order to enhance the service we provide to you. These parties may also need to process your personal data in the performance of their contract with us. Your personal information may be transferred electronically (e.g. by email or over the internet) and we, or any relevant third party, such as Carpenter Box Accountants may contact you in future by what we believe to be the most appropriate means of communication at the time (e.g. telephone/email /letter etc.).
The organisations to whom we may pass your details also have their own obligations to deal with your personal information appropriately. Sometimes a product or service may be administered from a country outside Europe. If this is the case, the firm must put a contract in place to ensure that your information is adequately protected.
As part of this agreement we will ask you to consent to the transfer of personal information in accordance with the protections outlined above.
Special categories of personal data:
- There are certain categories of personal data that are sensitive by nature. The categories include: data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and data concerning health. Depending on the nature of the products and services that you engage us for we may need to obtain some sensitive personal data, particularly in relation to health. Our policy is that, should we require any special category of personal data, we will only gather this with your explicit consent.
- If you are concerned about any aspect of our privacy arrangements please speak to us.
This privacy notice was last updated March 2023.