Privacy Policy

Introduction

This Privacy Policy is intended to help you understand:

  • What data we collect from you,
  • Why we collect it and
  • What we do with it.

This policy will explain how we store and use your personal information when you use or interact with our website, or where we otherwise obtain or collect your personal information.

This Privacy Policy applies to all services offered by us, except where otherwise noted.

This statement also explains how we protect any personal data we obtain directly or passively from you or which we obtain indirectly from other sources.

We have done our best to present the information in this policy in clear and plain language, and we have structured it in a way to allow you to quickly find the information that is most important to you.

We reserve the right to change our privacy statement from time to time.  We will update the Privacy Policy page content and last modified date on our website.  This privacy statement was last modified 25th May 2018.

Who are we?

Devonshire Wealth Management is a company incorporated and registered in England with company number 01302770.  We are the controller of personal data relating to our clients, processing personal data for the purposes of advising on a range of financial requirements.  

Privacy Statement

We are committed to keeping your personal data safe and to ensuring the integrity and security of any personal data we may process.

You should read this privacy notice very carefully as it contains important information on the way in which we will process your personal data, in particular:

  • The personal information we collect about you
  • Our legal bases for processing your personal information
  • What we do with your personal information
  • Who your personal information may be shared with
  • Your rights as a data subject under the data protection regulation

If you have any questions about this Privacy Policy, please contact our Data Protection Champion, Nicholas Townsend, [email protected], 76 New Cavendish Street, London, W1G 9TB, 020 7637 0666.

Our legal basis for processing your personal data

We may rely on a number of legal basis for collecting and further processing your personal data, which are:

  • Contractual Necessity
  • Legal Obligation
  • Legitimate Interest
  • Consent 

Contractual Necessity

We collect personal information about you when you request our products or services.   We will also process your personal data as necessary when entering into a contract with you or in order to take steps at your request prior to entering into a contract with you.

Legal Obligation

We may also process your personal information to allow us to comply with certain legal obligations and regulatory requirements to which we are subject i.e. FCA/HMRC etc.   We will work co-operatively and transparently with all relevant regulatory authorities, including the national data protection authority, the ICO, in relation to any data protection matters.

Legitimate Interest

We may use your personal data for our legitimate business interests, whilst carefully considering and balancing any potential impact on you and your rights as a data subject under the data protection regulation.

This may include processing your personal data to allow us to provide the best services and customer experience and to ensure our service remains relevant and tailored to your needs.

We will always ensure that our legitimate interests will never override your rights and freedoms under the data protection regulation.

As an example, we may rely on our legitimate interest to process your personal data for the following purposes:

  • To communicate important updates about our products or services, which we think may be of interest to you
  • For business development related activity such as contacting you by telephone or email to arrange meetings with our experts in relation to work or knowledge sharing
  • To enhance, modify, personalise or otherwise improve our services and communications for the benefit of you

In addition, we may use legitimate interests as our legal basis for processing where we may wish to perform statistical and other analysis on the personal data we collect.  This is to help us understand and improve on how our clients use our products or services.

Please note, you have the right to object to the processing for which we rely on legitimate interest as the legal basis.  You can do so by emailing [email protected]

Consent

We are required to gain your explicit consent prior to processing your data for any other purpose other than the original purpose for which it was gained.

We may also require your explicit consent where we process special category data about you (i.e. personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, genetic data, biometric data or data concerning health or sex life or sexual orientation).

Where we require such consent, we will provide you with sufficient information to allow you to make an informed decision.  We will ensure that we only gain consent via a clear and affirmative act, freely given by you that indicates your consent to specific purposes.

You have the right to withdraw your consent at any time and can do so by emailing [email protected]

Personal information we collect or obtain about you

We collect personal data relating to you and your use of our services from a variety of sources. These are detailed below.  Further sections of this Privacy Policy then describe what we do with this information.

Information gained directly from you

We will collect personal data, such as your name, address, business address, business and personal telephone numbers, business and personal email addresses and other details as per out fact find (a copy of which can be provided on request) via: Meetings, telephone calls and conversations, from business cards, when entering into a contract for our products and services.

We may also collect your personal data, which is gained indirectly or passively, such as:

  • Service data – personal data that are provided in the course of the use of our services
  • Enquiry data – information contained in any enquiry you submit to us regarding our services
  • Correspondence data – information contained in or relating to any communication that we have with you
  • Third party data – we may obtain data indirectly about you from publicly available sources and via third parties. The publicly available sources we may obtain personal data from you include:
    • Social media sites where you have a publicly accessible profile, such as LinkedIn
    • Companies House website
    • Your company website

We protect the data obtained from third parties according to the practices described in this statement.

Cookie notice

A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as items added in the shopping cart, visited pages or logging in options.

Cookies are widely used to make websites work, or to work more efficiently, and our site relies on cookies to optimise user experience and for features and services to function properly.

Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services.

You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu.

The types of cookie you can expect to see in use on our website are from:

  • Google Analytics – statistical analysis of website performance
  • Cloudflare – CDN, DNS, DDoS protection and security

You can choose to accept or decline cookies in your browser settings. Declining the use of cookies may prevent you from taking full advantage of the website.

How will we use your personal data?

We will only process your data where we have a legal basis to do so. We use data collected to communicate with you and to offer you our products or services. We may use your data to improve or maintain the services we offer to you. We will never share your data with any other third party, other than those stated in this policy, nor use your data for any other purpose, unless we firstly gain your explicit consent to do so.

You have the right to restrict the processing of your personal data. See below:

Who we share your data with

We do not share your personal data outside of the EU and we do not sell your personal data or other information to any third-party. 

Your rights as a data subject

As a data subject, you can exercise certain rights in relation to the processing of your personal data, such as:

  • The right to access the data we hold on you
  • The right to have incomplete data updated or inaccurate data corrected
  • The right to have your personal data erased
  • The right to restrict the processing or object to the processing of your personal data
  • The right to have your personal data transmitted to another data controller
  • The right to complain to the Information Commissioner’s Office (ICO)
  • The right to understand the source of data gained indirectly
  • The Right to be advised of any automated decision-making
Your Right What this means How you can exercise this right
The Right of Access You have the right to confirmation on whether or not we are processing your personal data and, where that is the case, access to that data, including the following information:

– The purpose of the processing

– The recipients or categories of recipient to whom the personal data have been or will be disclosed.

– The envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period

We shall provide a copy of the personal data being processed free of charge.

We will respond to your request within one month of your request.

We will advise any other recipients to whom the personal data has been disclosed.

You can request this information at no charge from us by emailing [email protected] or by telephoning 0207 637 0666
The Right to Rectification You shall have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you.

Taking into account the purposes of the processing, you shall also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

We will respond to your request within one month of your request.

We will advise any other recipients to whom the personal data has been disclosed.

You can request this information at no charge from us by emailing [email protected] or by telephoning 0207 637 0666
The Right to Erasure In some circumstances you have the right to have your personal data erased and no longer processed where:

– The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

– You withdraw consent on which the processing is based, and where there is no other legal ground for the processing;

– You object to the processing and there are no overriding legitimate grounds for the processing

– The personal data have been unlawfully processed;

– The personal data have to be erased for compliance with a legal obligation.

We will respond to your request within one month of your request.

We will advise any other recipients to whom the personal data has been disclosed.

You can request this information at no charge from us by emailing [email protected] or by telephoning 0207 637 0666
The Right to Restrict Processing You have the right to obtain the restriction of processing where one of the following applies:

– The accuracy of the personal data is contested, for a period enabling the verification of the accuracy of the personal data;

– The processing is unlawful and you object to the erasure of the personal data and request the restriction of their use instead;

– We no longer needs the personal data for the purposes of the processing, but are required by you for the establishment, exercise or defence of legal claims;

– You have objected to processing pending verification of whether our legitimate grounds override yours.

Where you have obtained restriction of processing you have the right to be informed by us before the restriction of processing is lifted.

We will respond to your request within one month of your request.

We will advise any other recipients to whom the personal data has been disclosed.

You can request this information at no charge from us by emailing [email protected] or by telephoning 0207 637 0666
The Right to Object You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on our legitimate interest.

You also have the right to object to processing for direct marketing purposes. Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

We will respond to your request within one month of your request.

We will advise any other recipients to whom the personal data has been disclosed.

To object to us processing your personal data for direct marketing or other legitimate interest purposes, please notify us by emailing [email protected] or by telephoning 0207 637 0666

This may take a maximum of 48 hours.

The Right to Data Portability You have the right to receive the personal data concerning you, which you have provided to us and have the right to transmit those data to another controller without hindrance from us to which the personal data have been provided, where:

– The processing is based on consent or on a contract and

– The processing is carried out by automated means.

Where feasibly possible, you also have the right to have the personal data transmitted directly to another controller.

We will respond to your request within one month of your request.

You can request this information at no charge from us by emailing [email protected]nshirewm.com or by telephoning 0207 637 0666
The Right to Complain You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) The contact details of the ICO are:

Website: ico.org.uk

Helpline: 0303 123 1113

The Right to Understand the Source of data gained indirectly. You have the right to be informed of the source of any personal data that are not collected directly from you You can request this information at no charge from us by emailing [email protected] or by telephoning 0207 637 0666
The Right to be advised of any Automated Decision-making Unless the information is necessary for entering into a contract with us, or you have given your explicit consent, you shall have the right not to be subject to a decision based solely on automated processing, which produces legal effects that affect you.

‘Automated decision-making’ is where a decision is made without human involvement, such without the need of human intervention.

We will respond to your request within one month of your request.

You can request this information at no charge from us by emailing [email protected]

 

 

 

Retention period

We will only keep your personal data for as long as necessary for the purposes for which it was gained.  We will review the personal data we hold on you in line with our retention policy, to check for accuracy and relevancy and to ensure we continue to have a legal basis for processing. If the personal data is no longer necessary, or where we no longer have the legal basis for processing we will delete or fully anonymise the data we hold on you, in line with our Data Protection Policy. If your data becomes inaccurate, we will update it accordingly.

Other websites

Our website may contain links to other websites which are outside its control and are not covered by this privacy statement. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their Privacy Policy, which may differ from ours. You must contact them to determine their Privacy Notice.

Security and Confidentiality

We are committed to transparency, ensuring that your privacy is protected and that your data is used and retained fairly, transparently and in compliance with the data protection regulation.

We will make sure that we have appropriate technical and organisational measures in place to keep your personal data secure and to protect against accidental or unlawful destruction, loss alteration, disclosure or access.  We will provide a level of security appropriate to the risk presented by the nature of the processing we do.

Data Champion

Our Data Champion’s contact details are:

Nicholas Townsend
76 New Cavendish Street, London, W1G 9TB
020 7637 0666
Email: [email protected]

Complaints

We will be more than happy to help should you have any complaints about the processing of your personal data. You have the right to lodge a complaint with the Supervisory Authority, the Information Commissioner Office (ICO), who are the national authority responsible for the protection of personal data.

A complaint can be made to the ICO via their website or through their helpline (0303 123 1113).

If you have any other queries or request concerning this privacy notice or your personal information or how we process it, please contact us via the contact details provided above.