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Libertas Financial Planning Ltd is part of Sense Network Ltd. This privacy notice explains how we use any personal information we collect about you.
What information do we collect about you?
We collect information about you when you request us to provide you with quotes for our services and engage us for financial planning. 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 relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.
We try at all times to keep at all personal data collected and processed accurate and up-to-date. We check the accuracy of data when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken to amend or erase that data, as appropriate.
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. 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. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
Why do we need to collect and use your personal data?
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.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with?
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 we share your personal data with our service providers we may allow them to process it as joint controllers under their privacy notices solely for the purposes of providing their services to us, complying with their own (and their affiliates, service providers, agents and delegates) legal obligations or pursuing their legitimate interest as described above in this privacy notice, but strictly in accordance with applicable laws. We do not allow our service providers to market to you for their own purposes unless they obtain your consent. In certain circumstances we or they may inform you about how you can access their privacy notices, which will give further information as to how they use your personal data and how you can exercise your rights in relation to your personal data.
Our primary service provider is Sense Network Ltd, our principal regulated firm and from whom we obtain professional support services and regulatory and business advice.
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. This is achieved by using secure portals requiring verification of each party using user names and passwords.
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.
If you agree, we may email you about other products or services that we think may be of interest to you.
We use tools supplied by 3rd parties for profiling customers and agreements are in place to protect your data in accordance with data protection laws and policies.
We won’t share your information for marketing purposes with companies outside our group of companies/other companies.
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 are also subject to regulatory requirements to retain your data for specified minimum periods.
These are, generally:
• Five years for investment business
• Three years for mortgage 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.
When determining the appropriate retention period, we consider the risks of the processing, our contractual, legal and regulatory obligations, internal retention policies and our legitimate business interests as described in this privacy notice.
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.
How can I access the information you hold about me?
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.
You may make a subject access request (“SAR”) at any time to find out more about the personal data which we hold about you. We are usually required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
All subject access requests must be sent to our Data Protection Officer.
We do not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
You also have the following rights in respect of your personal data:
• The right to be informed of the processing;
• The right to rectification;
• The right of erasure;
• The right to restrict processing;
• The right of data portability;
• The right to object to processing;
• The right to understand automated decision making and profiling.
For more details on how to exercise these rights please contact us.
When 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.
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.
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.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection.
In the UK this is:
Information Commissioner's Office
0303 123 1113 (local rate)
How to contact us
Or write to us at:
Libertas Financial Planning Ltd
8-10 Christchurch Road
Libertas Financial Planning Ltd is an appointed representative of Sense Network Limited which is authorised and regulated by the Financial Conduct Authority. Libertas Financial Planning Ltd is entered on the Financial Services register (www.fca.org.uk/register) under reference number 646934.
The information contained within the website is subject to the UK regulatory regime and is therefore primarily targeted at customers based in the UK.
The Financial Ombudsman Service is available to sort out individual complaints that clients and financial services business aren’t able to resolve themselves. To contact the Financial Ombudsman Service, please visit www.financial-ombudsman.org.uk.
Copyright © 2019 - Libertas Financial Planning Ltd - Companies House Registration No: 09197636. Registered in England and Wales. Registered address: 1st Floor, 8-10 Christchurch Road, Bournemouth, BH1 3NA.