What is Personal Information
When we refer to personal information, we mean information about an individual that can identify them, such as name, address, email address, telephone number and financial information. Any reference to information or data in this Policy is in reference to any personal information about a living individual.
Information We Collect
We collect and use personal information on the basis it is in our legitimate interests to do so. In operating our website, we may collect and process information we collect about you including information we get from your online browsing activity. We collect information via our account opening application process and throughout our relationship with you to fulfil our regulatory obligations and for the purpose of performing our contract with you. This includes face-to-face meetings, telephone conversations, email correspondence, or where you request literature or sign-up for newsletters. We may receive information if you have been dealing with a financial adviser or have been introduced to us by another party. We may record and monitor phone calls between us to fulfil our regulatory obligations and may obtain information from third-party service providers and from publicly available sources.
Use of Your Information
The information that we collect and store relating to you is primarily used to enable us to provide our services to you. Without it we may not be able to do so. We’ll process your personal information to carry out our responsibilities resulting from any agreements you’ve entered into with us and to provide you with information, products and services. We may use the information to develop and test the effectiveness of marketing activities and to improve our services. In addition, we may use it to provide you with marketing information about services and products we offer which may be of interest to you and to notify you about changes to our services and products. We may deliver this information by post, email, telephone or otherwise, including social media platforms. We may also use your name and address to post you invitations to events. You have the right to request us not to process your information for marketing purposes at any time by contacting us. If you no longer wish to be contacted for marketing purposes, please email us at email@example.com or write to us using the information at the end of this notice.
We may process your information to comply with any applicable legal or regulatory obligation we’re subject to, including “know your customer” checks for anti-money laundering purposes or to comply with any applicable regulatory reporting or disclosure requirements. If you are an existing client, we may contact you with information about our services. If you are a new client, we will only contact you when you have provided consent to receive information or services from us.
Storing Your Personal Data and Timeframe
Any personal information that we do obtain from you will be handled in accordance with data protection law. We’ll determine the length of time we keep it based on the minimum retention periods required by law or regulation. We will only keep your personal information after this period if there is a legitimate reason to do so.
Sharing Your Information
We will only disclose your information to associated companies within the Oberon Group. We may transfer information outside of the EEA but before doing so will take reasonable steps to enter into a suitable agreement with the recipient of the information and/or adopt any necessary measures in order to ensure an adequate level of protection with respect to your privacy rights and protection of your personal information in each case in accordance with applicable legislation.
If you have been dealing with a financial adviser, we may provide information about your dealings with us to enable the adviser to give you informed advice. We may be under a duty to disclose or share your information in order to comply with any legal obligation or regulatory requirements. This includes sharing information with any relevant authority where we are obligated to do so including, but not limited to, regulators, government (e.g. HRMC) and law enforcement or fraud prevention agencies.
We may provide information to service providers to enable us to fulfil our relevant checks for anti-money laundering purposes. We may provide information to our appointed auditors and other professional advisers to the extent that they require such information to provide advice.
In the event that we sell or buy any business or assets we may also disclose your information to the prospective seller or buyer of such business or assets. Otherwise, we may share information in order to enforce or apply the terms of any contract with us.
You have rights under data protection law that relate to the way we process your personal data. More information can be found on the Information Commissioner’s website. Broadly:
• You have the right to access the personal data we hold about you.
• You have the right to make us correct any inaccurate data we hold about you.
• The right (in certain circumstances) to make us erase any personal data we hold about you.
• The right (in certain circumstances) to restrict our processing of the personal data we hold about you.
• The right to object to our processing of personal data we hold about you.
• The right to receive personal data you have provided to us in a portable format or otherwise.
• The right to withdraw your consent where we are relying on it to use your personal data (e.g. for marketing purposes).
• request a copy of the information we hold about you, to request rectification, erasure.
Please note that any request for access may be subject to an administration fee at the prevailing rate which covers our costs in providing you with the information requested. Should you wish to receive details that we hold about you please contact us at the email address below.
Contacts and Complaints
If you have any questions about this Policy or wish to exercise any of your rights, please get in touch with us either at firstname.lastname@example.org or by writing to the Data Protection Officer at the following address:
2nd Floor, James House
1 Babmaes Street
We hope that you will never have reason to complain about the way we process your personal information or with the way we’ve handled a request by you in relation to your rights. However, if something does go wrong please bring it to our attention as soon as you can. We will try to resolve the matter fairly and quickly. Please contact us on the same details above. You also have the right to make a complaint to the Information Commissioner’s Office. Their address is:
Information Commissioner’s Office