General Data Protection Regulation
This privacy notice explains how Altorfer Financial Management Limited use any personal information we collect about you, our clients.
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, and in investments. 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’ll provide a copy of this privacy notice for them upon request. Alternatively, it can be accessed via our website.
Why do we need to collect and use your personal data?
The legal bases that we intend to use for the processing of your data is for the performance of our contract with you and compliance with the law. 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’d also be unable to fulfil our legal and regulatory obligations.
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. Your data may also be called upon if we need to defend a complaint made against us.
Who might we share your information with?
We won’t share your information for marketing purposes with other companies.
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’ll 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’ll only act in accordance with our or your instructions, or just from us if there is no direct relationship between them and you.
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.
We have a duty to share your information with government organisations such as HMRC, if they open an investigation into you, and we are provided with a legal notice.
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you and comply with our legal obligations. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re 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-out business
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it is appropriate to do so. In any case, we’ll not keep your personal data for longer than 6 years (other than for pension transfers as stated above) after your policy or investment has expired.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory and legal obligations 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’d 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. Where there is no ongoing relationship we will rely on you to notify us when a policy has expired.
Marketing
We do not undertake marketing, and we will not give or sell your details to other companies for marketing purposes.
Other Websites
Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
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
Changes to our privacy policy
We keep our privacy policy under regular review and place any updates on our website.
How to contact us
Please contact us if you have any questions about our privacy policy or information we hold about you:
By email at [email protected]
Or write to us at:
Compliance Officer
Altorfer Financial Management Limited
9 Regent Gate
Waltham Cross
Herts
EN8 7AF
Last updated 27/11/2020