Privacy Policy
INTRODUCTION
This Policy sets out how we use and protect your personal data.
Please take the time to read this Policy, which contains important information about the way in which we process personal data.
For the purposes of this Policy, “Data Protection Legislation” is defined as, for the periods in which they are in force and to the extent applicable to us, the General Data Protection Regulation (Regulation (EU) 2016/670) (“GDPR”), Data Protection Act 2018 (as amended from time to time), the UK legislation known as the “UK GDPR”, any equivalent legislation amending, supplementing or replacing the GDPR and any other law applicable to us and otherwise relating to data protection.
1. INFORMATION AND WHO WE ARE
This Policy gives you information about how and why we collect and use any personal data and provides information about individuals’ legal rights.
Controller
This Policy is issued on behalf of the Wealthtime Group so when we mention “we”, “us” or “our” in this Policy, we mean all the companies and businesses that make up the Wealthtime Group including their respective parent companies and subsidiaries. These include:
• Novia Financial plc t/a Wealthtime and/or Copia Capital Management
• Wealthtime Ltd
• Novia Financial Holdings Ltd
• Novia Financial Services Ltd
“You” and “yours”– depending on the context -refers to anyone who provides personal data to the Wealthtime Group including our customers, financial advisers and any individuals associated with them, discretionary fund managers (DFMs), contacts, suppliers, job applicants, staff, visitors to the Wealthtime Group’s websites and others who interact with us through social media or third-party links.
When we use your information, Novia Financial plc or Wealthtime Ltd will be the data controller and therefore responsible for looking after your information.
If you have any questions about this Policy and how we use your personal data, please contact us using the information set out in Section 11 (Contacts Details) below.
2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have set out below in a table format.
Data Category
Description
Behavioural (Usage) Data
Details about how you interact with our websites, products and services.
Contact Data
Data we use to contact you including but not limited to your billing address, delivery address, email address and telephone numbers.
Financial Data
Your bank account number/sort code, payment card details, the source of any funds you wish to invest, the source of your wealth and details of any previous investments or pensions you wish to transfer.
Identity Data
Data related to your identity or that could be used to identify you including your name, any previous names, username or similar identifier, address, marital status, date of birth, gender, passport number, national insurance number, photo ID (including passport and driving licence), video footage, occupation, place of work and employment history.
Marketing Data
Your preferences in receiving marketing/ newsletters from us and any relevant third parties and your communication preferences regarding these.
Open data and public records
Your data that is available from records such as the Electoral Register or Companies House or available openly on the internet.
Profile Data
Your username and password, details of the products and/ or services used by you and any interests, preferences, feedback or survey responses gathered from you.
Special Category Data
Sensitive data gathered in certain circumstance that could be used to identify you including data relating to health (including disabilities, access requirements etc.).
Technical Data
Your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and details of the devices and technology you use to connect to the Wealthtime Group’s Online Services and its websites.
Transactional Data
Details about payments to and from your accounts and the investments you buy, sell and hold within your products.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Behavioural (Usage) Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our websites to help improve the websites and our service offerings.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Your interactions with us: We collect personal data that you provide to us when you complete any of our application forms or supplementary forms, correspond with us by post, phone, email, secure messaging or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our websites;
• subscribe to our services 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 websites and services, we will also collect Technical, Transactional and Behavioural Data. We collect this personal data by using cookies[, server logs] and other similar technologies. Please see our Cookies Policy notice here for further details.
Third parties or publicly available sources: We also receive personal data about those who use our services and products from various third parties and public sources as set out below, including but not limited to:
• Financial advisers;
• Banks;
• Investment firms and fund managers;
• Stockbrokers, discretionary investment managers and DFMs;
• Financial institutions, pension schemes and investment providers;
• Credit reference and fraud prevention agencies;
• National and local government agencies such as HM Revenue & Customs;
• Publicly available sources such as Companies House;
• Solicitors and accountants;
• Employers; and
• Law enforcement and regulatory authorities.
4. HOW WE USE YOUR PERSONAL DATA
Legal Basis
We are only allowed to process your personal data (which includes storing it and sharing it with other companies) if we have a legal basis for doing so. The Data Protection Legislation outlines a number of legal base upon which we can rely to collect and use your personal data
Our processing of your data will always rely on one or more of the following reasons:
• Performance of a contract with you: Where we need to fulfil the terms of a contract we have or are about to enter into with you;
• Legal or regulatory obligations: We may use your personal data where it is necessary for compliance with a legal or regulatory obligations that we are subject to;
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to provide the best and most secure experience for our customers and clients. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law); and/ or
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter. You can withdraw your consent at any time by contacting either your normal business contact, marketing.team@wealthtime.com, or dataprotection@wealthtime.com although this may impact the service we can offer you.
Our processing of special category data will also consider one of more of the following reasons:
• Explicit consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose. You can withdraw your consent at any time by contacting either your normal business contact, marketing.team@wealthtime.com, or dataprotection@wealthtime.com although this may impact the service we can offer you.
• For legal reasons: We may use your personal data where it is necessary to comply with laws that include: employment, social security and social protection (if authorised by law, such as pension payments); legal claims or judicial acts; reasons of substantial public interest (this includes complying with certain financial or tax regulation); or health (including public health) or social care (with a basis in law).
Our privacy promise
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways in which we may use your personal data, and the legal basis/ bases we rely on when doing so including our legitimate interests where appropriate.
Purpose / use of your data
Our legal basis / bases
To register you as a new customer/ client of ours.
Performance of a contract with you. Necessary to comply with our legal and regulatory obligations.
To provide our products and services and administer your accounts with us.
Performance of a contract with you.
To manage our relationship with you including notifying you about changes to our Terms of Business, Terms and Conditions or this Policy and to deal with requests, complaints and queries.
Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. Necessary for our legitimate interests (to keep our records update and manage our relationship with you).
To provide training on our services.
To update you on changes or inform you of our business details such as names/trading names, addresses etc.
Necessary for consideration of legitimate interests (to ensure service users understand our services and utilise their features effectively).
Necessary for consideration of legitimate interests (to ensure that service users can communicate with us effectively).
To produce our reports (including variations and portfolio analysis), accounts and management information (MI) and to undertake audits and reviews.
Performance of a contract with you. Necessary to comply with our legal and regulatory obligations.
To make records of written and verbal communication between our customers and financial adviser clients, where applicable.
Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. Consent.
To enable us to contact and send information to employees, agents and contractors of suppliers and other parties with whom we have relationships in relation to the use of our products and services.
Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. Consent. Necessary for our legitimate interests (for running our businesses, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
To report relevant information to national / local government bodies and regulatory authorities.
Necessary to comply with our legal and regulatory obligations.
To make back-ups of personal data gathered and store this for use in emergency situations.
Necessary to comply with our legal and regulatory obligations.
To identify you and validate the information you provide to us.
Performance of a contract with you. Necessary to comply with our legal and regulatory obligations.
To process and manage payments (including pension payments), facilitate orders (including investment orders), complete reconciliations, record transfers and re-registrations of assets and monies and collect and recover any monies owed to us.
Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. Necessary for our legitimate interests (to recover debts due to us).
To enable us to monitor accounts and to help prevent financial crime.
Performance of a contract with you. Necessary to comply with our legal and regulatory obligations.
To enable us to determine, when necessary, whether pension benefits may be taken earlier than the normal minimum pension age (NMPA) because of injury, sickness, disease or disability or to comply with our legal and regulatory obligations.
Performance of a contract with you. Necessary to comply with our legal and regulatory obligations.
To administer and protect the Wealthtime Group’s businesses and its websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Necessary to comply with our legal and regulatory obligations. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
To deliver relevant website content to our customers and clients.
Performance of a contract with you.
To send you relevant marketing communications and make personalised suggestions and recommendations to you about products or services that may be of interest to you based on your Profile Data.
Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business). Consent.
To allow our business partners including event and roadshow partners to send you relevant marketing communications and make personalised suggestions and recommendations to you about their products or services.
Consent.
To register you for events and webinars and enable you to partake in prize draws, competitions or complete surveys.
Performance of a contract with you. Consent. Necessary for our legitimate interests (to promote and grow our business, study how customers use our products/services, to develop them).
Asking you to leave a review or to carry out market research through your voluntary participation in surveys.
To provide a more tailored service to you so that we can better meet your needs.
Necessary for our legitimate interests (to study our customers/clients use our products/ services and to help us improve and develop these).
Explicit consent.
Direct Marketing
Unless we have a legitimate interest, you will receive marketing communications from us only where you have provided us with your consent to do so.
Opting Out of Marketing
You can ask us to stop sending you marketing communications at any time by clicking the unsubscribe button at the bottom of our email communications or by contacting us at marketing.team@wealthtime.com.
Cookies
Our websites use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our websites. To find out more about how we use cookies, please see our Cookies Policy notice here.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal information where necessary with the parties set out below for the purposes set out in the table above:
• Financial advisers and third-party organisations which they have appointed under a written agreement.
• Our offshore bond providers.
• Banks.
• Insurers.
• Investment firms and fund managers.
• Stockbrokers, discretionary investment managers and DFMs.
• Credit reference and fraud prevention agencies.
• National and local government agencies such as HM Revenue & Customs, the Department of Work and Pensions, Job Centre Plus.
• Financial institutions, pension schemes and investment providers to whom you wish to re-register or transfer your assets and monies.
• The UK Financial Ombudsman Scheme, The Pensions Ombudsman, the UK Financial Services Compensation Scheme (FSCS), Financial Conduct Authority (FCA) and The Pensions Regulator.
• Law enforcement and other regulatory authorities.
• Market research companies for the purpose of improving our services.
• Auditors, lawyers, bankers, consultants and other professional service firms who act on our or your behalf.
• Any other companies or individuals you request that we share your information with; and
• Other companies where we have a joint venture, or an agreement to co-operate with them including our business partners and those we partner with for events and roadshows.
In addition, we may need to share your personal data with other organisations in order to be able to provide the products and services that you have requested, including:
• Service and technology providers that enable us to run and provide our products and services efficiently s including server suppliers, software licensors and providers of transaction services.
• Direct Debit Schemes and BACS; and
• Our printing and mailing suppliers.
We may also share your personal data if the ownership or structure of the Wealthtime Group changes in the future, for example where we decide to sell, transfer or merge certain parts of our business or acquire other businesses to merge with. If a change in our structure or ownership happens, then other parties may use your data in the same way as set out in this notice.
6. INTERNATIONAL TRANSFERS
We will only send your data outside the United Kingdom (“UK”) or European Economic Area (EEA) where it is necessary to:
• Fulfil an instruction you have given us;
• Comply with a legal or regulatory duty; or
• To work with the technology and service providers that help run our Wealthtime Group products and services.
• Whenever we transfer data outside ofthe UK or EEA, we will ensure that these are countries that the UK Government and the European Committee has deemed to have an adequate level of protection for personal data, we may also put in place UK International Data Transfer Agreements and EU Standard Contractual Clauses for transfers outside of the UK or EEA, meaning that the data will be given the same level of protection as it has in the UK.
• Our people may access our systems remotely when working within or outside of the UK. Where they do so, they are required to use our systems and access any personal data in accordance with all the usual policies and procedures.
7. DATA SECURITY
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 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 require all third parties to respect the security of your personal data and to treat it in accordance with the law.
8. DATA RETENTION
How long will we keep your personal information?
We will retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers. We have the right to retain customer data for a minimum period of time after we cease to provide our services but may keep this data for longer if we cannot delete it or need to retain it still for legal, regulatory or technical reasons.
In some circumstances you can ask us to delete your data: see Section 9. (Your Legal Rights) below for further information.
9. YOUR LEGAL RIGHTS
You have a number of rights under the Data Protection Legislation in relation to the personal data we hold about you.
You have the right to:
• Request access to your personal data (commonly known as a “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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object;
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in Section 4 (How we use your personal data) for details of how to object to receiving direct marketing communications);
• 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us using our contact details in Section 11 (Contact Details) below.
Can you refuse to provide data to the Wealthtime Group?
It is your personal data, so you are always free to decide whether you provide this data to the Wealthtime Group. If you choose not to give us personal data, however, this may prevent us from fulfilling our obligations and could result in delays or mean that we cannot perform certain tasks necessary to administer your products and services. In these cases, we may have to refuse to provide you with new products or services or cancel a product or service you have with us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the above rights) unless we believe your request(s) to be manifestly unfounded, excessive or repetitive. Before any charge is imposed, we will contact you to discuss if there is a more appropriate way to meet your access request. We may also refuse to comply with requests that are clearly unfounded, repetitive, or excessive.
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 will endeavour to answer all requests we receive without delay and at the latest within one month of receipt. 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.
10. COMPLAINTS
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using our contact details in Section 11 below.
11. CONTACT DETAILS
If you have any questions about this Policy or about the use of your personal data or you want to exercise your privacy rights, please contact our Head of Compliance in the following ways:
• Email address: dataprotection@wealthtime.com
• Postal address: FAO: Compliance Team, Cambridge House, Henry Street, Bath BA1 1JS
12. CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our Policy under regular review and may change it from time to time. If we do so, the latest version will always be made available on our websites and will become effective immediately.
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, for example a new address or email address.
13. THIRD-PARTY LINKS
The Wealthtime Group’s websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy policy of every website you visit.
14. DISCLAIMER
This Policy is for information only and whilst efforts have been made to ensure that it is accurate and current, we provide no guarantee as to its accuracy. We accept no liability for loss or damage suffered as a result of reliance on the information provided in this Policy.
INTRODUCTION
This Policy sets out how we use and protect your personal data.
Please take the time to read this Policy, which contains important information about the way in which we process personal data.
For the purposes of this Policy, “Data Protection Legislation” is defined as, for the periods in which they are in force and to the extent applicable to us, the General Data Protection Regulation (Regulation (EU) 2016/670) (“GDPR”), Data Protection Act 2018 (as amended from time to time), the UK legislation known as the “UK GDPR”, any equivalent legislation amending, supplementing or replacing the GDPR and any other law applicable to us and otherwise relating to data protection.
1. INFORMATION AND WHO WE ARE
This Policy gives you information about how and why we collect and use any personal data and provides information about individuals’ legal rights.
Controller
This Policy is issued on behalf of the Wealthtime Group so when we mention “we”, “us” or “our” in this Policy, we mean all the companies and businesses that make up the Wealthtime Group including their respective parent companies and subsidiaries. These include:
• Novia Financial plc t/a Wealthtime and/or Copia Capital Management
• Wealthtime Ltd
• Novia Financial Holdings Ltd
• Novia Financial Services Ltd
“You” and “yours”– depending on the context -refers to anyone who provides personal data to the Wealthtime Group including our customers, financial advisers and any individuals associated with them, discretionary fund managers (DFMs), contacts, suppliers, job applicants, staff, visitors to the Wealthtime Group’s websites and others who interact with us through social media or third-party links.
When we use your information, Novia Financial plc or Wealthtime Ltd will be the data controller and therefore responsible for looking after your information.
If you have any questions about this Policy and how we use your personal data, please contact us using the information set out in Section 11 (Contacts Details) below.
2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have set out below in a table format.
| Data Category | Description |
| Behavioural (Usage) Data | Details about how you interact with our websites, products and services. |
| Contact Data | Data we use to contact you including but not limited to your billing address, delivery address, email address and telephone numbers. |
| Financial Data | Your bank account number/sort code, payment card details, the source of any funds you wish to invest, the source of your wealth and details of any previous investments or pensions you wish to transfer. |
| Identity Data | Data related to your identity or that could be used to identify you including your name, any previous names, username or similar identifier, address, marital status, date of birth, gender, passport number, national insurance number, photo ID (including passport and driving licence), video footage, occupation, place of work and employment history. |
| Marketing Data | Your preferences in receiving marketing/ newsletters from us and any relevant third parties and your communication preferences regarding these. |
| Open data and public records | Your data that is available from records such as the Electoral Register or Companies House or available openly on the internet. |
| Profile Data | Your username and password, details of the products and/ or services used by you and any interests, preferences, feedback or survey responses gathered from you. |
| Special Category Data | Sensitive data gathered in certain circumstance that could be used to identify you including data relating to health (including disabilities, access requirements etc.). |
| Technical Data | Your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and details of the devices and technology you use to connect to the Wealthtime Group’s Online Services and its websites. |
| Transactional Data | Details about payments to and from your accounts and the investments you buy, sell and hold within your products. |
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Behavioural (Usage) Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our websites to help improve the websites and our service offerings.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Your interactions with us: We collect personal data that you provide to us when you complete any of our application forms or supplementary forms, correspond with us by post, phone, email, secure messaging or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our websites;
• subscribe to our services 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 websites and services, we will also collect Technical, Transactional and Behavioural Data. We collect this personal data by using cookies[, server logs] and other similar technologies. Please see our Cookies Policy notice here for further details.
Third parties or publicly available sources: We also receive personal data about those who use our services and products from various third parties and public sources as set out below, including but not limited to:
• Financial advisers;
• Banks;
• Investment firms and fund managers;
• Stockbrokers, discretionary investment managers and DFMs;
• Financial institutions, pension schemes and investment providers;
• Credit reference and fraud prevention agencies;
• National and local government agencies such as HM Revenue & Customs;
• Publicly available sources such as Companies House;
• Solicitors and accountants;
• Employers; and
• Law enforcement and regulatory authorities.
4. HOW WE USE YOUR PERSONAL DATA
Legal Basis
We are only allowed to process your personal data (which includes storing it and sharing it with other companies) if we have a legal basis for doing so. The Data Protection Legislation outlines a number of legal base upon which we can rely to collect and use your personal data
Our processing of your data will always rely on one or more of the following reasons:
• Performance of a contract with you: Where we need to fulfil the terms of a contract we have or are about to enter into with you;
• Legal or regulatory obligations: We may use your personal data where it is necessary for compliance with a legal or regulatory obligations that we are subject to;
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to provide the best and most secure experience for our customers and clients. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law); and/ or
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter. You can withdraw your consent at any time by contacting either your normal business contact, marketing.team@wealthtime.com, or dataprotection@wealthtime.com although this may impact the service we can offer you.
Our processing of special category data will also consider one of more of the following reasons:
• Explicit consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose. You can withdraw your consent at any time by contacting either your normal business contact, marketing.team@wealthtime.com, or dataprotection@wealthtime.com although this may impact the service we can offer you.
• For legal reasons: We may use your personal data where it is necessary to comply with laws that include: employment, social security and social protection (if authorised by law, such as pension payments); legal claims or judicial acts; reasons of substantial public interest (this includes complying with certain financial or tax regulation); or health (including public health) or social care (with a basis in law).
Our privacy promise
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways in which we may use your personal data, and the legal basis/ bases we rely on when doing so including our legitimate interests where appropriate.
| Purpose / use of your data | Our legal basis / bases |
| To register you as a new customer/ client of ours. | Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. |
| To provide our products and services and administer your accounts with us. | Performance of a contract with you. |
| To manage our relationship with you including notifying you about changes to our Terms of Business, Terms and Conditions or this Policy and to deal with requests, complaints and queries. | Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. Necessary for our legitimate interests (to keep our records update and manage our relationship with you). |
| To provide training on our services.
To update you on changes or inform you of our business details such as names/trading names, addresses etc. |
Necessary for consideration of legitimate interests (to ensure service users understand our services and utilise their features effectively).
Necessary for consideration of legitimate interests (to ensure that service users can communicate with us effectively). |
| To produce our reports (including variations and portfolio analysis), accounts and management information (MI) and to undertake audits and reviews. | Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. |
| To make records of written and verbal communication between our customers and financial adviser clients, where applicable. | Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. Consent. |
| To enable us to contact and send information to employees, agents and contractors of suppliers and other parties with whom we have relationships in relation to the use of our products and services. | Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. Consent. Necessary for our legitimate interests (for running our businesses, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). |
| To report relevant information to national / local government bodies and regulatory authorities. | Necessary to comply with our legal and regulatory obligations. |
| To make back-ups of personal data gathered and store this for use in emergency situations. | Necessary to comply with our legal and regulatory obligations. |
| To identify you and validate the information you provide to us. | Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. |
| To process and manage payments (including pension payments), facilitate orders (including investment orders), complete reconciliations, record transfers and re-registrations of assets and monies and collect and recover any monies owed to us. | Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. Necessary for our legitimate interests (to recover debts due to us). |
| To enable us to monitor accounts and to help prevent financial crime. | Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. |
| To enable us to determine, when necessary, whether pension benefits may be taken earlier than the normal minimum pension age (NMPA) because of injury, sickness, disease or disability or to comply with our legal and regulatory obligations. | Performance of a contract with you. Necessary to comply with our legal and regulatory obligations. |
| To administer and protect the Wealthtime Group’s businesses and its websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | Necessary to comply with our legal and regulatory obligations. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). |
| To deliver relevant website content to our customers and clients. | Performance of a contract with you. |
| To send you relevant marketing communications and make personalised suggestions and recommendations to you about products or services that may be of interest to you based on your Profile Data. | Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business). Consent. |
| To allow our business partners including event and roadshow partners to send you relevant marketing communications and make personalised suggestions and recommendations to you about their products or services. | Consent. |
| To register you for events and webinars and enable you to partake in prize draws, competitions or complete surveys. | Performance of a contract with you. Consent. Necessary for our legitimate interests (to promote and grow our business, study how customers use our products/services, to develop them). |
| Asking you to leave a review or to carry out market research through your voluntary participation in surveys.
To provide a more tailored service to you so that we can better meet your needs. |
Necessary for our legitimate interests (to study our customers/clients use our products/ services and to help us improve and develop these).
Explicit consent. |
Direct Marketing
Unless we have a legitimate interest, you will receive marketing communications from us only where you have provided us with your consent to do so.
Opting Out of Marketing
You can ask us to stop sending you marketing communications at any time by clicking the unsubscribe button at the bottom of our email communications or by contacting us at marketing.team@wealthtime.com.
Cookies
Our websites use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our websites and also allows us to improve our websites. To find out more about how we use cookies, please see our Cookies Policy notice here.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal information where necessary with the parties set out below for the purposes set out in the table above:
• Financial advisers and third-party organisations which they have appointed under a written agreement.
• Our offshore bond providers.
• Banks.
• Insurers.
• Investment firms and fund managers.
• Stockbrokers, discretionary investment managers and DFMs.
• Credit reference and fraud prevention agencies.
• National and local government agencies such as HM Revenue & Customs, the Department of Work and Pensions, Job Centre Plus.
• Financial institutions, pension schemes and investment providers to whom you wish to re-register or transfer your assets and monies.
• The UK Financial Ombudsman Scheme, The Pensions Ombudsman, the UK Financial Services Compensation Scheme (FSCS), Financial Conduct Authority (FCA) and The Pensions Regulator.
• Law enforcement and other regulatory authorities.
• Market research companies for the purpose of improving our services.
• Auditors, lawyers, bankers, consultants and other professional service firms who act on our or your behalf.
• Any other companies or individuals you request that we share your information with; and
• Other companies where we have a joint venture, or an agreement to co-operate with them including our business partners and those we partner with for events and roadshows.
In addition, we may need to share your personal data with other organisations in order to be able to provide the products and services that you have requested, including:
• Service and technology providers that enable us to run and provide our products and services efficiently s including server suppliers, software licensors and providers of transaction services.
• Direct Debit Schemes and BACS; and
• Our printing and mailing suppliers.
We may also share your personal data if the ownership or structure of the Wealthtime Group changes in the future, for example where we decide to sell, transfer or merge certain parts of our business or acquire other businesses to merge with. If a change in our structure or ownership happens, then other parties may use your data in the same way as set out in this notice.
6. INTERNATIONAL TRANSFERS
We will only send your data outside the United Kingdom (“UK”) or European Economic Area (EEA) where it is necessary to:
• Fulfil an instruction you have given us;
• Comply with a legal or regulatory duty; or
• To work with the technology and service providers that help run our Wealthtime Group products and services.
• Whenever we transfer data outside ofthe UK or EEA, we will ensure that these are countries that the UK Government and the European Committee has deemed to have an adequate level of protection for personal data, we may also put in place UK International Data Transfer Agreements and EU Standard Contractual Clauses for transfers outside of the UK or EEA, meaning that the data will be given the same level of protection as it has in the UK.
• Our people may access our systems remotely when working within or outside of the UK. Where they do so, they are required to use our systems and access any personal data in accordance with all the usual policies and procedures.
7. DATA SECURITY
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 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 require all third parties to respect the security of your personal data and to treat it in accordance with the law.
8. DATA RETENTION
How long will we keep your personal information?
We will retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers. We have the right to retain customer data for a minimum period of time after we cease to provide our services but may keep this data for longer if we cannot delete it or need to retain it still for legal, regulatory or technical reasons.
In some circumstances you can ask us to delete your data: see Section 9. (Your Legal Rights) below for further information.
9. YOUR LEGAL RIGHTS
You have a number of rights under the Data Protection Legislation in relation to the personal data we hold about you.
You have the right to:
• Request access to your personal data (commonly known as a “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 in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object;
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in Section 4 (How we use your personal data) for details of how to object to receiving direct marketing communications);
• 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us using our contact details in Section 11 (Contact Details) below.
Can you refuse to provide data to the Wealthtime Group?
It is your personal data, so you are always free to decide whether you provide this data to the Wealthtime Group. If you choose not to give us personal data, however, this may prevent us from fulfilling our obligations and could result in delays or mean that we cannot perform certain tasks necessary to administer your products and services. In these cases, we may have to refuse to provide you with new products or services or cancel a product or service you have with us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the above rights) unless we believe your request(s) to be manifestly unfounded, excessive or repetitive. Before any charge is imposed, we will contact you to discuss if there is a more appropriate way to meet your access request. We may also refuse to comply with requests that are clearly unfounded, repetitive, or excessive.
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 will endeavour to answer all requests we receive without delay and at the latest within one month of receipt. 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.
10. COMPLAINTS
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using our contact details in Section 11 below.
11. CONTACT DETAILS
If you have any questions about this Policy or about the use of your personal data or you want to exercise your privacy rights, please contact our Head of Compliance in the following ways:
• Email address: dataprotection@wealthtime.com
• Postal address: FAO: Compliance Team, Cambridge House, Henry Street, Bath BA1 1JS
12. CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our Policy under regular review and may change it from time to time. If we do so, the latest version will always be made available on our websites and will become effective immediately.
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, for example a new address or email address.
13. THIRD-PARTY LINKS
The Wealthtime Group’s websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy policy of every website you visit.
14. DISCLAIMER
This Policy is for information only and whilst efforts have been made to ensure that it is accurate and current, we provide no guarantee as to its accuracy. We accept no liability for loss or damage suffered as a result of reliance on the information provided in this Policy.
Talk to our team today
Your financial adviser should always be your first port of call for any questions you have about your account, however, we’re always happy to help.
For Wealthtime platform queries, call
0345 680 8000
For Wealthtime Classic platform queries, call
03330 417 010
To make a complaint, click the relevant platform below: