This policy is effective from 20th August 2012.
Policy last updated 25th May 2018 (Data Protection Officer)
2. What data do we collect about you?
3. How we collect your data
4. How we use your data
5. Disclosure of your data to Third Parties
6. The security and accuracy of your data
7. How long we will keep your data
8. Your rights regarding the data we hold about you
9. How you can complain about the way we are using your data
This includes any data you may provide to us either through one of our websites (if you complete one of our website contact forms; use our LiveChat system; request a download document or sign up to a newsletter) or communicate with us in any way through telephone calls, emails, text messages, or postal services.
1.2 Location of Company
Wilmott Turner is operated from the United Kingdom. If you visit one of our websites or use one of our services from outside the U.K., you agree to any processing of any personal information you provide us according to this policy.
1.2 Links to other websites
Any website owned and operated by Wilmott Turner is not intended for children and we do not knowingly collect data relating to children.
1.4 Data Protection Officer
If you have any questions about this privacy notice or any requests regarding your personal data held by us please contact the Wilmott Turner Data Protection Officer using the following details:
Date Protection Officer: James Falla
Telephone: 0800 088 7376
Post: The Data Protection Officer, Wilmott Turner Financial Services Limited, 116 Springfield Road, Windsor, Berkshire. SL4 3PS
2.1 Anonymous Data gathered while using our Websites
We collect anonymous data from every visitor of any Wilmott Turner website to monitor traffic and fix bugs. For example we collect information like web requests, the data sent in response to such requests, the Internet Protocol (IP) address, the browser type, the browser language, and a timestamp for the request. No personal details are obtained in this process and your identity is not revealed in any way.
2.2 Cookie Data
A cookie is a small file which asks permission to be placed on your computer tablet or mobile. The cookie file helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Overall cookies help us provide you with better websites by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you other than the data you choose to share with us.
2.3 User Profile Data
In order to take advantage of certain features of our websites (for example our forums or LiveChat function), you may choose to provide us with personal data to allow you to create a user profile. We will then save your profile and the documents and comments associated with it.
The data that you may be asked to provide in these instances is likely to include your name and e-mail address.
Your decision to utilize these features and provide such information will always be voluntary. If you log in and create a profile on any of our websites, you are able to view, change and remove the date associated with your profile at any time.
Should you choose to delete an account you have created on any Wilmott Turner website and are unable to do this yourself for any reason, please contact the Data Protection Officer (see 1.4 above).
2.4 Personal Data
In order to take advantage of the services we provide to you we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender, your employment status and occupation.
Sensitive Personal Data includes details about your health, family life and dependants.
Contact Data includes servicing address, residential address, email address and telephone numbers.
Financial Data includes bank account and payment card details, national insurance, your income, expenditure, assets, banking transactions, debts and other liabilities and any legal or other recovery action taken against you in respect of your debts.
Transaction Data includes details about payments to and from you and other details of products and services you have obtained from us.
Profile Data includes purchases or orders made by you, feedback and survey responses.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.5 Data regarding your Family Members & Dependants
We may need to collect personal data about your family members and dependants in order to be able to advise you effectively or for the purposes of performing a contract with you. If this is necessary you shall ensure that you have the consent of the person(s) concerned to enable the lawful transfer of their personal data to us for this purpose
This includes giving them notice that personal data relating to them may be:
We use different methods to collect data from and about you:
3.1 Direct Interactions
You may give us your Identity, Sensitive, Contact and Financial Data (see 2.4 above) by filling in forms, through meetings with us or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
3.2 Automated Technologies or Interactions
As you interact with any of our websites we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
3.3 Third Parties or Publicly Available Sources
We may receive personal data about you from various third parties and public sources as set out below:
4.1 Lawful Grounds
Wilmott Turner will use your personal data for the following purposes and based on the following lawful grounds:
We will use your data for the following genuine and legitimate reasons which allow us to give you the best service and the best experience:
Performance of a Contract
We will use your data in the following ways where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
We will use your data in the following ways where it is necessary for compliance with a legal or regulatory obligation that we are subject to. For example:
4.2 Marketing and Promotional Offers
Wilmott Turner will only use your personal information to send you promotional information about services provided by ourselves or third parties where you have previously given your consent to receive such communications.
Where you have previously given consent but no longer want to receive such communication from Wilmott Turner please contact our Data Protection Officer (section 1.4) who will remove your details from our files.
Where you opt out of receiving marketing messages, we will continue to use your data in accordance to section 4.1 above.
4.3 Aggregated Data
We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
4.4 Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer (section 1.4).
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required to fulfill a legal obligation.
5.1 External Third Parties
While using your data for the purposes set out in section 4 we may have to share your personal data with external third parties. These may include the following
Unless we tell you differently, our Service Providers do not have any right to use Personal Information or other information we share with them beyond what is necessary to provide the service you have requested.
5.2 Social Media
Social media buttons provided by services like Twitter, Google+, LinkedIn and Facebook can be found on some Wilmott Turner websites.
Your use of these third party services is entirely optional. We are not responsible for the privacy policies and/or practices of these third party services, and you are responsible for reading and understanding those third party services’ privacy policies.
5.3 Buying and Selling Assets
We may choose to buy or sell assets. In these types of transactions both client and user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, client and user information would be one of the assets that is transferred or acquired by a third party.
You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your personal information as set forth in this policy.
6.1 The Security of your Data
Once you have submitted it to us Wilmott Turner will keep the data we collect from you securely. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6.2 The Accuracy of your Data
We are not responsible for keeping your data accurate and up to date. Where your circumstances change and you feel that the data we hold is no longer accurate and you are using or intend to use our services it is your responsibility to inform us accordingly.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data. See section 8 below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8.1 Your Legal Rights
You have various rights in regard to your personal data. These include
8.1.1 Subject Access Request
This is your right to request a copy of the personal data we hold about you and to check that we are lawfully processing it. This is known as a Subject Access Request.
8.1.2 Request a Correction of your Data
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
8.1.3 Request Erasure of your Data
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
8.1.4 Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
8.1.5 Withdrawal of your consent to use your data
You can at any time withdraw your consent to process your personal data where we were relying on this consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
8.2 Fees Payable
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
8.3 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
8.4 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint about the way we are using your personal data at any time. Such a complaint should be made to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
The ICO can be contacted in the following ways:
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF
Telephone: 0303 123 1113