DATA PRIVACY NOTICE
Aquila Financial Management Ltd is a company registered in England and Wales (No. 41988077) whose
registered office is at The Summit, Woodwater, Park, Pynes Hill, Exeter, EX2 5WS is authorised and
regulated by the Financial Conduct Authority.
Aquila Financial Management Ltd Financial Services Register number is 161585.
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 engage us for financial planning 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.
CCTV
We operate closed circuit television (CCTV) to provide security for staff, visitors and property. We may,
where appropriate, also process this data for the prevention of crime. Please contact us if you require
further information.
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 will 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 would also be
unable to fulfil our legal and regulatory obligations.
Where special category data is required, we will 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.
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 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.
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 do we protect your data?
We take protecting your data very seriously. With this in mind we will treat your data with the utmost care
and take all appropriate steps to protect it. We have clear data protection and information security policies
and procedures in place (along with Regulatory and other legal obligations to keep your data safe) and
these are regularly assessed as part of our compliance processes.
We protect our IT system from Cyber Attack. Access to your personal data is password-protected, and
sensitive data is secured by encryption.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration
testing to identify ways to further strengthen security.
How long do we keep hold of your information?
During the course of our relationship with you we will retain personal data which is necessary to provide
services to you. We will 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-outs
• Three years for insurance business
These are minimum periods, during which we have a legal obligations to retain your records.
We reserve the right to retain data for longer where we believe it is in our legitimate interests to do so.
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.
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 would like a copy
of some or all of your personal information please email or write to us using the contact details noted
below.
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.
Marketing
We may, in the future, wish to send you information about our products and services 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. If you no longer wish
to be contacted for marketing purposes, please contact us by email or post.
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 we will inform you of any changes when they occur.
A current copy will be held on our website www.aquilafm.co.uk. This privacy policy was last updated on
6th June 2024.
How to contact us
Please contact us if you have any questions about our privacy policy or information we hold about you:
By email to:
[email protected]
Or write to us at:
Aquila Financial Management Ltd
The Summit
Woodwater Park
Pynes Hill
Exeter
EX2 5WS
