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Customer Privacy Notice

 

Why should you read this document?

 

During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

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What do we mean by “Your Personal Data”?

 

Your Personal Data means any information that describes or relates to your personal circumstances.   Your Personal Data may identify you directly, for example your name, address, date of birth, National Insurance number.

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Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

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In the context of providing you with assistance in relation to your investment/financial planning, pensions and/or insurance requirements Your Personal Data may include:

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  • Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses  and documents that are necessary to verify your identity.

  • Employment and remuneration information (including salary/bonus schemes/overtime/sick pay/other benefits).

  • Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents.

  • Health status and history, details of treatment and prognosis, medical reports.

  • Any pre-existing investment/pension and/or insurance products and the terms and conditions relating to these.

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Certain types of personal information such as ethnic origin, religious beliefs, physical or mental health are treated as a separate category of data (Your Special Data).  We will use Your Special Data only where it is necessary to provide you with a product or service and in the same way as Your Personal Data generally, as set out in this Privacy Notice.

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The basis upon which our Firm will deal with Your Personal Data

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

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1).  Processing is necessary to perform our contract with you. When we speak with you about your investment/financial planning, pensions and/or insurance requirements, we do so on the basis that both parties are entering a contract for the supply of services.  In order to be able to provide these services to you, and to arrange the products you require, we require use of Your Personal Data.

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2).  Processing is necessary for our legitimate interests. In the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we will process Your Personal Data provided we have a legitimate business interest to do so and your rights are not affected.  For example, we may need to respond to requests from product providers or our compliance auditor relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.

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3).  Processing is necessary to comply with our legal obligations.  On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject.  In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.

 

How do we collect Your Personal Data?

 

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to investment/financial planning, pensions and/or insurance.  You will provide information to us verbally and in writing, including email.

 

We may also obtain some information from third parties, for example information from your employer, and searches of information in the public domain such as the voters roll.  If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status we will only do this if we have consent from you for us or our nominated processor to access your information in this manner.

 

With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

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Cookies

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Our website host uses “cookies” to track visitor use of the website and compile statistical reports on website activity. Cookies are small files which are saved on your computer or other device when you visit our website.  Cookies store small pieces of information.  For instance, they may remember you've visited the website or performed a certain action. 

 

You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, note that some parts of the website may not function properly.

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What happens to Your Personal Data when it is disclosed to us?

 

In the course of handling Your Personal Data, we will:

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  • Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.

  • Submit Your Personal Data to Product Providers, both in paper form and online via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that providers may raise.

  • Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investment/pension product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.

 

Sharing Your Personal Data

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From time to time Your Personal Data will be shared with:

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  • Investment, pension and insurance providers.

  • Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to compliance advisers, product specialists, accountants, providers of legal services such as estate planners and software providers.

 

In each case, Your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your investment/financial planning, pension and/or insurance enquiry and to provide you with our professional services. 

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Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

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We envisage that in the performance by us of our service the majority of Your Personal Data will be processed within the European Economic Area.  However from time to time some of your information may be processed by the third parties we work with outside of the EEA, including countries such as the United States.

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Security and Retention of Your Personal Data

 

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities.

 

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

 

Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have a legal right to retain such information we will retain records indefinitely.

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Your rights in relation to Your Personal Data

 

You can:

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  • request copies of Your Personal Data that is under our control

  • ask us to further explain how we use Your Personal Data

  • ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)

  • ask us to send an electronic copy of Your Personal Data to another organisation should you wish

  • change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

 

How to make contact with our Firm in relation to the use of Your Personal Data

 

If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it, please contact:

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Damon Rainsford

Rainsford Financial Planning Ltd.

9 Hills Road

Cambridge

CB2 1GE

email:  damon@rainsfordfp.com

tel:      01223 785 476

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You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

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If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

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