Privacy Policy & GDPR 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.

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) or 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).

In the context of providing you with assistance in relation to your Investment, Pension and/or Protection Policy, your Personal Data may include:

• 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 and employment history
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependants
• Health status and history, details of treatment and prognosis, medical reports
• Any pre-existing Investment, Pension and/or Protection Policy products and the terms and conditions relating to these

The Basis Upon Which Our Firm Will Deal with Your Personal Data

When we speak with you about your Investment, Pension and/or Protection Policy requirements we do so on the basis that both parties are entering a contract for the supply of services. In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed in this notice.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected.

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.

Special Category and Criminal Disclosure Data

Where you ask us to assist you with your insurance needs, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you for information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance providers and to provide you with advice regarding the suitability of any product that may be available to you.

The arrangement of certain types of insurance may involve disclosure of information relating to historic or current criminal convictions or offences. This is relevant to insurance related activities such as underwriting, claims and fraud management.

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. This includes any information you provide to us when filling in forms (including website contact forms), and also information sent to us by email, post, telephone, messages or provided to us at a face to face or video meeting.

We may also obtain some information from third parties, for example credit checks, information from your employer, and searches of information in the public domain such as the voters roll.

Artificial Intelligence (AI)

To enhance the quality, efficiency and accuracy of our services, we use AI to assist with:

• Recording and transcribing meetings, although you can opt out of being recorded
• Generating meeting notes and summaries
• Drafting correspondence and documentation
• Conducting checks for compliance with internal procedures

We are committed to protecting your privacy and ensuring that any information processed is handled securely. If you have any questions or concerns about the AI we use in relation to your personal information, please contact us.

What Happens to Your Personal Data When It Is Disclosed to Us?

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

• Record and store Your Personal Data in our paper files, mobile devices and on our computer systems. This information can only be accessed by employees and consultants within our Firm when it is necessary to provide our service to you.
• Submit Your Personal Data to Product Providers, both in paper form and online via a secure portal, to progress any enquiry or application made on your behalf.
• Use Your Personal Data for the purposes of responding to any queries you may have in relation to any Investment, Pension and/or Protection Policy you may take out.

Sharing Your Personal Data

From time to time Your Personal Data will be shared with Investment, Pension and/or Protection Policy Providers, and third parties who we believe will be able to assist us with your enquiry or application. These third parties include but are not limited to our Compliance Advisers, Product specialists, estate agents, and providers of legal services.

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 will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

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 legal right to such information we will retain records indefinitely.

Your Rights in Relation to Your Personal Data

You can:

• 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
• 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

How to Make Contact With Our Firm

If you have any questions or comments about this document, or wish to exercise any of your rights, please contact:

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the ICO at ico.org.uk or by writing to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Declaration

For your own benefit and protection you should read these terms carefully. By proceeding, you grant Secure Asset Funds Europe Limited full authority to process your personal data for the purpose stated in this Privacy Notice.