Aquila Financial Management Ltd is a company registered in England and Wales (No. 41988077) whose registered office is at Aquila Financial Management Ltd, The Summit, Woodwater Park, Pynes Hill, Exeter, Devon 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.
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 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
- 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 have the 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)
Website
In terms of our Website, please note the following additional points:
Your acceptance of these Privacy Statement terms
By using any of the sites within our website network (“Websites”) or our Services, you unconditionally agree to be bound by this Privacy Policy.
What data do we collect and how do we use it?
Aquila Financial Management collects and processes information about you in order to:
1. identify you each time you visit a Website
2. improve our Services and Websites
3. carry out research on the demographics, interests and behaviour of all of our customers
Log files/IP addresses
When you visit our Websites, we automatically log your IP address (the unique address which identifies your computer on the internet) which is automatically recognised by our web server. We use IP addresses to help us administer our Websites and to collect broad demographic information for aggregate use. We do not link IP addresses to personally identifiable information.
Non-personal information
We may automatically collect non-personal information about you such as the type of internet browsers you use or the site from which you linked to our Websites. You cannot be identified from this information and it is only used to assist us in providing an effective service on our Websites. We may from time to time supply the owners or operators of third party sites from which it is possible to link to our Websites with information relating to the number of users linking to our Websites from their sites. You cannot be identified from this information.
Security
Aquila Financial Management places a great importance on the security of all information associated with our customers. We have security measures in place to attempt to protect against the loss, misuse and alteration of customer data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to user information. While we cannot ensure or guarantee that loss, misuse or alteration of data will not occur, we use our best efforts to prevent this.
Where is the information stored?
Information which you submit via our Websites or our telephone services is stored on a computer located in the European Economic Area. This is necessary in order to process the information and to send you any information you have requested.
Information submitted by you may be transferred by us to our other offices and to reputable third party suppliers, which may be situated outside the European Economic Area. Not all countries outside the EEA have data protection or privacy laws. In addition, if you use our Services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those Services.
Updates to Website
From time to time, we will make changes to our Website. This, and our commitment to protecting the privacy of your personal information, may result in periodic changes to this Privacy Policy. As a result, please remember to refer back to this Privacy Policy regularly to review any amendments.
Contact Us
Please e-mail any questions, concerns or comments you have about our Privacy Policy to Aquila Financial Management or write to us at:
Aquila Financial Management Ltd
The Summit
Woodwater Park
Pynes Hill
Exeter
Devon
EX2 5WS
advice@aquilafm.co.uk
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