This privacy notice explains how Lonsdale Services use any personal information we collect about you. Please note that Lonsdale Wealth Management, Lonsdale benefit consultants and Lonsdale Mortgages are trading names of Lonsdale Services.
What information do we collect about you?
We collect information about you when you engage us for financial planning/financial advice/mortgage advice/investment management services. This information will relate to your personal and financial circumstances. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
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 will use your information collected from the website to personalise your repeat visits to the site.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
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.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect technical data which may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below.
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 would also be unable to fulfil our legal and regulatory obligations. We may also use your personal data where necessary for our legitimate interest and your interests and fundamental rights do not override those interests. 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?
You will receive our newlsetter from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that newsletter. If you agree, we may email you about other products or services that we think may be of interest to you. You have the right to withdraw consent to marketing at any time by contacting us.
We will not 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 or marketing 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 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 will only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit. For example all personal data we transfer by email will be password protected where possible.
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.
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented :
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data for as long as reasonably necessary to provide services to you, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re 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-outs
- 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 or in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. In any case, we’ll not keep your personal data for longer than 25 years after our relationship with you has ended.
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 and what are your rights in relation to your data?
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you would like a copy of some or all of your personal information, or exercise any of the rights set out, please email or write to us using the contact details noted below.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Automated decision making and profiling
If you use our initial or review process 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 don’t 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.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In March 2018 Lonsdale Services achieved Cyber Essentials certification. It is a Government- backed industry supported scheme which helps organisations protect themselves against common online threats.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We would like to send you information about Lonsdale Services products and services which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date. However, please note that the Lonsdale Services newsletter is included as part of our ongoing client service contract with you and is not considered marketing information.
You have a right at any time to stop us from contacting you for marketing. If you no longer wish to be contacted for marketing purposes, please speak to your financial adviser or contact us by post or email us.
For further information visit 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.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the cookies we use and the purposes for which we use them in the table below:
Strictly necessary cookies
Google Analytics cookies
We use Google Tracking cookies to customise visitors’ experiences while browsing. ;Our use of Google Analytics requires us to pass to Google your IP address (but no other information) – Google uses this information to prepare site usage reports for us, but Google may also share this information with other Google services. In particular, Google may use the data collected to contextualise and personalise the ads of its own advertising network. Related information:
Other third-party tracking cookies
From time to time we may install other third-party tracking cookies such as HotJar. We use these types of cookies to tailor the visitor experience while using the website. These cookies will expire when we delete the tracking facility from our website. Third-party cookies can be disabled by changing your browser preferences.
What can you do if you do not agree 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)
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
How to contact us
3 Curo Park