As the operators of the website (“www.primewealth.co.uk”), Prime Wealth ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “Data Protection Laws”) the Data Controller is Prime Wealth Planning Limited trading as Prime Wealth.
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of [e.g. your use of the website or providing our services]:
The provision of your name, address and date of birth, as well as other personal data is required from you to enable Us to fulfil our regulatory and legal obligations. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
INFORMATION WE COLLECT FROM OTHER SOURCES
When acting on your behalf we will also obtain personal data from other sources if required, for example:
USES MADE OF YOUR INFORMATION
Lawful basis for processing
We rely on your consent as provided when you sign up to using our Services as the lawful basis on which We collect and use your personal data. Our legitimate interests in this data are to fulfil our contractual obligations to you and to fulfil our legal obligations as authorised and regulated firms.
Purposes of processing
We use information held about you in the following ways:
In addition to the above uses We may use your information to notify you about goods or services which may be of interest to you. Where We do this, We will contact you by electronic means (e-mail or SMS) only if you have consented to such communication. If you have not consented to such communication, or if previously We haven’t had any contact with you, we will write to you at the business address. Our communications do not impact your right to object and you can opt out of further communications at any time by either (i) ticking the relevant box situated on your service charter on which We collect your data ; (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.
If you are not a current Prime Wealth client and have received communication that you previously hadn’t asked for we will have sent you this information on a legitimate interest basis. We will have identified you as benefiting from a possible service we could provide which we believe will benefit you or your business. This contact does not affect your right to object and you can opt out at anytime by contacting Glen Callow at firstname.lastname@example.org or 0121 711 6353.
DISCLOSURE OF YOUR INFORMATION
We routinely disclose your personal data to third parties as follows:
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by accessing this data through the wealth platform portal, or by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by [e.g. sending a request by email to the contact details below].
We will endeavour to update your personal data within 7 working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
Where we store your personal data
All of the information that We hold about you is stored on our secure servers within the EEA.
If you would like further information please contact US or the Compliance Director at Best Practice IFA Group Limited, of which we are an Appointed Representative (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
HOW TO COMPLAIN
We hope that We or our Compliance Director can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may collect information about [your mobile phone, computer or other device from which you access the Website] including where available [your IP address, operating system and browser type], for systems administration [and to report aggregate information to third parties affiliates]. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
The cookies We use include:
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
11. CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be updated on our website.
This privacy notice was last updated in May 2018.
12. CONTACT US
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to email@example.com write to Us at Prime Wealth, Corner Oak, 1 Homer Road, Solihull, B91 3QG. Or alternatively please contact our Compliance Director at Best Practice IFA Group Ltd, Sussex House, North Street, Horsham, West Sussex, RH12 1RQ, telephone number 01403 334455, or via email at firstname.lastname@example.org