IDENTITY & CONTACT DETAILS OF THE CONTROLLER & THE CHIEF PRIVACY OFFICER
Ludlow Wealth Management Group and associated companies (Ludlow (Cheshire), Ludlow (Fylde) Ludlow (Preston), and our Appointed Representatives Napthens Wealth Management and DRN Financial Management), herein collectively referred to as LWMG, are committed to protecting and respecting your privacy whilst remaining compliant with The General Data Protection Regulation (EU GDPR) and the Data Protection Act (DPA). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
LWMG, are the Data Controller and Processor and have an appointed a Data Officer whom can be contacted via email: Data@ludco.co.uk
You can also contact us by post at: 172 Lord Street, Southport, Merseyside. PR9 0QA
PURPOSE OF THE PROCESSING AND THE LEGAL BASIS FOR THE PROCESSING
LWMG, collects and creates personal client data to enable us to provide financial advice to our clients.
The legal basis for processing personal data for the purpose of business development is the pursuit of our legitimate interest in developing our business and the provision of advice to our clients, which will also involve establishment of financial services products to help meet their goals. We acquire personal data from a number of sources including directly from data subjects, from referrals and from public sources such as Linked In. We will retain personal information we collect through our advice processes indefinitely where we have provided advice to clients due to the regulatory requirements of the Financial Conduct Authority, and legal risks associated with the provision of financial advice.
Provision of services to our clients
The legal basis for processing personal data for the purpose of providing services to our clients is either to fulfil our contractual obligations to clients or the pursuit of related legitimate interests including maintaining accurate records relating to accounting and finance, and monitoring the quality of our services. We will retain personal information we collect through our service delivery processes for as long as such information is relevant to our service delivery model, and in conjunction with regulatory requirements under the Financial Conduct Authority.
We are required to obtain consent from individuals in order to send them unsolicited electronic marketing messages. We retain evidence of the details of consent which has been provided by our customers to process their information in this manner.
LEGITIMATE INTERESTS OF LWMG
LWMG may use your information for other specific legitimate purposes such as:
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have either explicitly consented to or we believe you have a legitimate interest in.
- To carry out our obligations arising from any contracts entered between you and us.
- To notify you about changes to our service.
We do not sell, rent or lease customer lists to third parties.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Information that you provide during advice meetings with your adviser, or by corresponding with us by phone, email or otherwise. The information you give us may include:
- Name and Company Name
- Email address
- Telephone numbers
- Health details
- Existing Policy Information
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of your visits to our web site and the areas that you access.
RECIPIENTS OF THE PERSONAL DATA
LWMG are required to transfer the personal information provided by its customers to third parties in order to fulfil contractual obligations. The following are categories of recipients that client information could be transferred to:
- Customer relationship management (CRM)
- Data Centres
- Product Providers
- External IT Providers
- Payment Providers
- Accountancy Services
- Corporate Partners that have referred you to LWMG
All information you provide to us is stored on our secure servers. However, 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 our site; 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.
We may disclose your personal information to any member of our group (Ludlow Wealth Management Group Limited), which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We will not disclose your information to any of the relevant third parties listed above for marketing purposes.
Our Data Officer can provide you with contact details of our third parties upon request if required. You can do this by emailing our Data Officer at Data@ludco.co.uk
DETAILS OF TRANSFERS TO THIRD COUNTRIES & SAFEGUARDS
LWMG store personal data on information systems that ensure all personally identifiable information held on our clients remains within the EEA.
LWMG retain all client information indefinitely once advice has been provided. This is because of the regulatory framework we work under, and the requirement to be able to demonstrate suitability of advice for the lifetime of our clients.
RIGHTS OF DATA SUBJECTS
As a Data Subject (individual) which LWMG process information on behalf of, you have the right to request access to, and the rectification or erasure of personal data that we hold about you as well as a right to object to and to a restriction of our processing of your personal data at any given time. You can do this through the contact details provided on page 1 of this policy. You can exercise the right at any time by contacting us at Data@ludco.co.uk
Please note however as FCA regulated advisers we are required to retain records relevant to our advice to you and this can supercede your right to have all data deleted under the General Data Protection Regulation.
You also have a right to lodge a complaint with the Supervisory Authority (Information Commissioners Office (ICO) in the UK – at www.ico.org.uk), should you feel that we have not handled your information in line with legislative and regulatory requirements.
You have the right to make a Data Subject Access Request to LWMG Data Officer if you wish to determine what information we hold on you. We welcome these requests and aim to respond within 72 working hours of receipt.
AUTOMATED DECISION MAKING, INCLUDING PROFILING & INFORMATION ABOUT HOW DECISIONS ARE MADE, THE SIGNIFICANCE OF THE CONSEQUENCES
We use email monitoring services to monitor the emails which we send to users. In doing this, we obtain information such as but not limited to:
- Time of receipt.
- Time of opening.
- Device user to open.
- Location it was opened in.
- Which parts of the email you interacted with.
We use systems that enable us to link your social media accounts to your account if registered with the same email address. This enables us to tailor our promotions and products as best as possible.
We may collect information about your computer, including where available your IP address, geographic location (if you allow when prompted by your browser), operating system and browser type, for system administration when you access our website. We use this information for statistical data about our users’ browsing actions and patterns when they access our website.
In the event that you wish to you alter your Privacy settings or opt-out, you are able to do this by emailing our Data Officer at Data@ludco.co.uk Our Data Officer shall provide you with contact details of our third parties upon request if required.
We may send out email communication such as our newsletter to keep you up to date with developments in financial services, newsletters and budget updates. If you wish to unsubscribe from these emails you can do so at any time by simply clicking either of the links in the header or footer and you will be removed from all promotional emails.
Please note that even if you decide not to subscribe to, or to unsubscribe, from promotional email messages, we may still need to contact you with important information related to your financial situation and our services to you. For example, even if you have unsubscribed from our promotional email messages, we will still send you updates relating to the services for which we are engaged to provide to you.
This document was last updated on 16th May 2018.