Privacy Notice
Who we are
The website address is: http://cleverlyplanned.co.uk/site. It belongs to Cleverly Planned Limited and is hosted in a secure UK data centre. As a conscientious independent financial advice firm we take looking after your data seriously.
What personal data we collect and why we collect it
As independent financial advisers, we need to know you well in order to provide a good service.
Cleverly Planned Ltd is an appointed representative of Sense Network Ltd. This privacy notice explains how we use any personal information we collect about you.
What information do we collect about you?
We collect information about you when you request us to provide you with quotes for our services and engage us for financial planning/financial advice/investment management services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.
If you send a message to us via the form on our website it is sent by email via a secure socket layer. When we receive it we will be able to view your email address, name and message. We will use this to respond to your enquiry and will keep a copy of the email in line with this privacy policy.
We try at all times to keep at all personal data collected and processed accurate and up-to-date. We check the accuracy of data when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken to amend or erase that data, as appropriate.
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
Why do we need to collect and use your personal data
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with?
If you agree, we may email you about other products or services that we think may be of interest to you.
If you agree, we’ll pass on your personal information to our group of companies so that they may offer you their products and services.
We use tools supplied by 3rd parties for profiling customers and agreements are in place to protect your data in accordance with data protection laws and policies.
We won’t share your information for marketing purposes with companies outside our group of companies.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit, Such as encrypted data file transfers and password protected documents.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
- Five years for investment business
- Three years for mortgage business
- Indefinitely for pension transfers and opt-out business
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so. You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all your personal information, please email or write to us using the contact details noted below.
You may make a subject access request (“SAR”) at any time to find out more about the personal data which we hold about you. We are usually required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
All subject access requests must be sent to our Data Protection Officer.
We do not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
You also have the following rights in respect of your personal data:
- The right to be informed of the processing;
- The right to rectification;
- The right of erasure;
- The right to restrict processing;
- The right of data portability;
- The right to object to processing;
- The right to understand automated decision making and profiling.
For more details on how to exercise these rights please contact us.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
Cookies
We use cookies to track visitor use of the website and to compile statistical reports on website activity.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
Other websites
Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113 (local rate)
Changes to our privacy policy
We keep our privacy policy under regular review and inform you of any changes when they occur. This privacy policy was last updated on 01/06/2019
How to contact us
Please contact us if you have any questions about our privacy policy or information we hold about you: by email at sophie@cleverlyplanned.co.uk
Or write to us at Cleverly Planned Ltd, 22a Victoria Road, Saltaire, Shipley, BD18 3LQ
We are registered with the Information Commissioner’s Office and you can see our entry on the register here.
Cleverly Planned Ltd is registered in England & Wales. Registered number: 11930628. Registered office: 22A Victoria Road, Saltaire, Shipley, West Yorkshire, BD18 3LQ. Cleverly Planned Ltd is an appointed representative of Sense Network Ltd which is authorised and regulated by the Financial Conduct Authority. Cleverly Planned Ltd is entered on the Financial Services Register here under reference 842889.
Cleverly Planned Ltd, independent financial advisers helping people put pensions and investments into real-life context. The information contained within this website is subject to UK regulatory regime and is therefore restricted to consumers based in the UK.
The Financial Ombudsman Service is available to sort out individual complaints that clients and financial services business aren’t able to resolve themselves. To contact the Financial Ombudsman Service, please visit www.financial-ombudsman.org.uk.