Harrogate Wealth Management Limited respect the privacy of our customers and the confidentiality of your personal information.

Harrogate Wealth Management Limited is a company that provides Independent Financial Advice to Individuals, Companies and Trustees and are directly authorised and regulated by the Financial Conduct Authority (FCA number 742739). Harrogate Wealth Management is a limited company registered in England (09965163). Registered address is Windsor House, Cornwall Road, Harrogate, North Yorkshire HG1 2PW.

Harrogate Wealth Management Limited (“we”, “us” or “our”) is committed to protecting and respecting your privacy. This privacy policy sets out how we collect, store and use your personal data when you provide it to us, Harrogate Wealth Management Limited is the data controller in respect of your personal data.

This Privacy Notice explains:

• who we are
• what personal information do we collect?
• how we use your personal information?
• who we share your information with and why?
• what processes do we have in place to keep your information secure?
• your rights
• how to contact us

What personal information do we collect?

Personal information includes your name, address or phone number and other information that is not otherwise publicly available. We collect personal information about you when you contact us about products and services, see or speak to one of our financial advisors or when you visit our website.

The type of personal information we collect will depend on the purposes for which it is collected and includes:

• Contact details
• Information to verify your identity
• Family, lifestyle, health and financial information
• Payment details

We will collect this personal information directly from you. For example, we ask for personal information at the start of our relationship and in subsequent communications, in order to check your identity and protect you from fraud. This is a legal requirement and is important to help safeguard you against potential crime.

‘Special Category’ information

In some instances, it is necessary to collect more sensitive information (such as detailed health or lifestyle information) which is called special category data. This is to allow us to provide our individually tailored financial advice service to you. We will always obtain your consent during the advice process to gather this data and explain what information we require and why it is needed. Sensitive personal information will always be processed and stored securely. It is possible to withdraw your consent at any time to us processing this data; however, this is likely to mean that you can no longer access the service or product the information was gathered for.

What are Cookies?

We also collect information about you from other sources. For example, our website automatically collects information from your computer using ‘cookies’, which provides us with limited personal information. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the website owners. For further information, visit www.aboutcookies.org or www.allaboutcookies.org

What data will we retain?

We keep your personal information only as long as is necessary for the purpose for which it was collected and to meet regulatory or legislative requirements. Personal information will be securely disposed of when it is no longer required.

Why do we collect data?

The processing of your personal data is allowed under a number of lawful bases. The data required for the provision of products and services is processed on the basis there is a contract with you to do so.

Any relevant marketing activity we undertake is done because as a firm we have a legitimate interest to do so, however you have rights, as listed below, which impact how we can use and process your data.
 
How we will use your personal information?

We process your information in order to support and maintain our contractual relationship with you and to comply with legal and regulatory requirements. This includes the following:

• providing our advice, products or services to you
• carrying out transactions you have requested
• confirming and verifying your identity for security purposes
• credit scoring and assessment, and credit management (where applicable)
• detecting and preventing fraud, crime, money laundering or other malpractice

We also process your data for specific business purposes to enable us to give you the best products and services and the best and most secure experience. For example, we may process your information to send you marketing that is tailored to your needs and interests.

Our business purposes include the following:

• enhancing, modifying, and personalising our services for the benefit of our customers
• providing communications which we think will be of interest to you
• market or customer satisfaction research or statistical analysis
• audit and record keeping purposes
• enhancing the security of our network and information systems

You have the right to object to this processing if you wish, please see ‘YOUR RIGHTS’ section below. Please bear in mind that if you object this may affect our ability to carry out the tasks above for your benefit.

Who do we share your information with and why?

We share your information with trusted third parties who perform tasks for us and help us to provide the services you require these include:

• third parties to verify your identity, in line with money laundering or other requirements (this may involve carrying out checks with credit reference databases);
• third parties who perform tasks for us to help us set up or service your plan (these third parties may be based in countries outside the European Economic Area (EEA) but where they are, we will undertake an assessment of safeguards in place);
• other organisations, including regulatory bodies, the police and fraud prevention agencies, to prevent and detect fraud;
• third parties where required by law, court order or regulation; and
• third parties as part of an acquisition or sale.

What processes do we have in place to keep your information secure?

We are committed to ensuring the confidentiality of the personal information that we hold, and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure.

If we work with third parties in countries outside the EU we ensure these are countries that the European Commission has confirmed have an adequate level of protection for personal information, or the organization receiving the personal data has provided adequate safeguards.

In limited circumstances data may be accessed outside of the EEA i.e. by employees when they travel.  In these circumstances we ensure there are appropriate information security measures in place to safeguard your information.

Your rights

Harrogate Wealth Management attempts to be as open as it can be in terms of giving people access to their personal information and therefore have outlined your rights below.

For more information about your data protection rights please, this can be accessed via: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Marketing

You have the right to opt out of marketing information and tell us what your communication preferences are by contacting Harrogate Wealth Management Limited using the details provided at the end of this notice or by using the opt out option below or on any email marketing. You may opt out at any time if you don’t want to receive any further communications of this nature.

Your individual data rights

The purposes of the processing;

• The right to be informed - you can request that we provide ‘fair processing information’, typically through this privacy notice;
• The right of access - you may request a copy of the personal information we hold about you, using the contact details found at the end of this policy;
• The right to rectification - the accuracy of your personal information is important to us. You have the right to ask us to update or correct your personal information;
• The right to erasure – you may request the deletion or removal of personal data where there is no compelling reason for its continued processing;
• The right to object – you may object to the processing of your data based on legitimate interests;
• The right to restrict processing - you have a right to request we ‘block’ or suppress processing of your personal data;
• The right to data portability – you may request to obtain and reuse your data; and
• The right not to be subject to automated decision-making including profiling.

If you wish to correct, restrict, delete or make changes to your personal information, or any of the data subject rights listed above, please contact us at the number/address listed below.

How to contact us

If you have questions about this notice, need further information about our privacy practices, or wish to give or withdraw consent, exercise preferences or correct your personal information, please contact us using the following details.

Lee Hurst
Harrogate Wealth Management Limited
Windsor House
Cornwall Road
Harrogate
HG1 2PW

Tel 01423 530277
Email info@harrogatewealth.co.uk

How to complain

If you wish to raise a complaint about how we have handled your personal data, you can contact Lee Hurst, Harrogate Wealth Management Limited’s Compliance Officer who will investigate the matter.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time

If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to our regulator:

Information Governance Department
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113

www.ico.org.uk/concerns