How we use your data.
This privacy notice explains how we use personal information we collect about you.
What information do we collect about you?
We collect information about you when you engage with us for financial advice. 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 collect information when you voluntarily complete client surveys or provide feedback to us.
Information relating to usage of our website is collected when you visit and communicate with us, complete forms or make a purchase. Information may also include the resources you access, but is not limited to traffic data, location data, weblogs and other communication data.
Why do we need to collect and use personal data?
The lawful basis that we intend to use for the processing of your data is for the ‘Performance of a Contract’ or ‘Legitimate Interests’. The information that we collect about you is essential for us to be able to effectively carry out the services that you require from us. In addition, without collecting your personal data, we would be unable to fulfil our legal and regulatory obligations. Where special category or sensitive data is required, we will obtain your explicit consent in order to collect and process this information. This information may be about physical or mental health, lifestyle choice, racial origin, political beliefs etc. and we will obtain your consent before processing any sensitive personal data.
If we give information about another person, then we will confirm that he/she has given their consent for us to act on their behalf.
How will we use the information about you?
We collect information about you to provide you with the services for which you engage with us.
Who might we share your information with?
If you agree, we may contact you about other products or services that we think may be of interest to you.
If you agree, we will pass on your personal information to other Prosperity companies, especially if you move jurisdiction, so that you will receive ongoing services; they may also offer you their own products and services.
This consent to transfer your data to a new controller will be obtained at the time of your relocation and will require you to sign a Data Transfer Form.
We will not share your information for marketing purposes with companies outside our Insights of companies.
In order to deliver services to you effectively, we may send your details to third party providers, such as those 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, including those based outside of the European Economic Area (EEA) we will 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 will only act in accordance with our written instructions.
Where it is necessary for your personal data to be forwarded to a third party, we will use appropriate security measures to protect your personal data in transit. This could include password protection and/or encryption of data. Administration services are outsourced and provided by deVere Group back office administration, based in Malta.
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?
In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. We reserve the right to retain data for longer under the legal basis of ‘Legitimate Interests’. In any case, we will not retain your personal data for longer than 5 years past the time of your death.
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and Legitimate Interests as noted above.
Your Individual Rights
You have a right of access to your information. We will provide your information within one month of your request without charge. In order to do this, please contact your local Data Protection Officer.
You have the right of data portability. 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.
You have the right of rectification meaning we have an obligation to ensure your personal information is accurate and up to date. If you believe your data is inaccurate, please notify us and we will rectify this for you.
You have the right to restrict processing. Should you contest the accuracy of the data held about you, in some circumstances, we can restrict data processing.
You have the right to object to your data being used in certain circumstances, for example, direct marketing.
You have rights relating to automated decision making, which means you have the right to not be subject to decision making based solely on automated processing.
You have the right of erasure which is to request the deletion of your data from our system, although we will only be able to comply where it does not conflict with our regulatory requirements.
We would like to send you information about our products and services and those of other companies in the Insights which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes or giving information to other members of the Insights. If you no longer wish to be contacted for marketing purposes, please contact us by email or post by writing to the address given.
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What can you do if you are unhappy with how your personal data is processed?
You also have the right to lodge a complaint with the supervisory authority for data protection.
How to contact us