Why should you read this document?

During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

What do we mean by “Your Personal Data”?

Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date of birth, national insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

In the context of providing you with assistance in relation to your Investment/Mortgage/Finance and/or Insurance requirements Your Personal Data may include:

  • Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
  • Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
  • Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
  • Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
  • Any pre-existing investment/mortgage/finance and/or insurance products and the terms and conditions relating to these

The basis upon which our firm will deal with Your Personal Data

When we speak with you about your investment/mortgage/finance and/or insurance requirements we do so on the basis that both parties are entering a contract for the supply of services.

In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.

On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.

The basis upon which we will process certain parts of Your Personal Data

Where you ask us to assist you with for example your insurance / ethical investments, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance / investment providers in relation to insurance products that may meet your needs and to provide you with advice/guidance regarding the suitability of any product that may be available to you.

If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.

The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.

We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.

Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to investment/mortgages/finance and insurance. You will provide information to us verbally and in writing, including email.

We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

What happens to Your Personal Data when it is disclosed to us?

In the course of handling Your Personal Data, we will:

  • Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
  • Submit Your Personal Data to Product Providers/Mortgage Lenders/Commercial Lenders and/or Insurance Product providers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
  • Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investment/mortgage/finance product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.

Sharing Your Personal Data

From time to time Your Personal Data will be shared with:

  • Investment providers / Mortgage lenders / Finance lenders / Insurance providers
  • Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our compliance advisers, product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).

In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress your investment/mortgage/finance and/or insurance enquiry and to provide you with our professional services.

Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.

Security and retention of Your Personal Data

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper form for a minimum period of 6 years following the advice/service you receive from us, although your data could be held for a longer period where this may be needed to meet the requirements of our regulatory bodies.

Your rights in relation to Your Personal Data

You can:

  • request copies of Your Personal Data that is under our control
  • ask us to further explain how we use Your Personal Data
  • ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
  • ask us to send an electronic copy of Your Personal Data to another organisation should you wish
  • change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

How to make contact with our Firm in relation to the use of Your Personal Data

If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
Sean McDermott – LightSide Financial Planning Ltd

If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Visitors to our Website

Here you’ll find information on how we treat data that we collect from visitors to our website, when someone submits a contact form or when someone subscribes to our newsletter.

When someone visits our website we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns.

We collect information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit, entry and exit points and the number of page views).

We do this to find out things such as the number of visitors to the various parts of the site.

This information is only processed in a way which does not identify anyone.

We do not make and do not allow Google to make, any attempt to find out the identities of those visiting our website.

You can find more information on how cookies are used on this website in the Cookies Policy below.

If we do want to collect personally identifiable information through our website, we will be upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

When You Contact Us Via Our Contact Forms

Our website has forms built using Gravity Forms.

The personal information we collect might include your name, phone number, email address, IP address, and information regarding what pages are accessed and when.

When you use our contact form the information submitted emailed to us so that we can correspond with you. Your personal data will be stored in the website’s database. Your data is encrypted with the Gravity Forms Encrypted Fields plugin before it is saved to the database.

We store your data on our website database so that if an email doesn't get through we can check the website and access the request to ensure we don't miss any enquiries or leads.

Security

Our website has HTTPS encryption via a Let's Encrypt SSL certificate to ensure any data passed between your browser and the web server (where this website is hosted) is encrypted. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.

Data Retention

Your data saved in the website database will automatically be deleted 1 year after submission.

This website and its database are automatically backed up every day using a third party service ManageWP. Backups are stored for 90 days in the EU Region.

Mailing List

We use MailChimp for our newsletter campaigns. MailChimp are GDPR compliant.

When you subscribe to our mailing list we collect your email address, name and marketing permissions consent. Your personal data will be stored in our mailing list provider, MailChimp, the application we use to send our newsletters. By clicking to subscribe to the mailing list, you acknowledge that the information you provide will be transferred to MailChimp for processing in accordance with their Privacy Policy and Terms.

Your data on MailChimp will be kept for the duration the business is running and we are utilising a newsletter. You can request to be removed anytime by clicking 'unsubscribe' in any newsletter/mailout or by emailing info@lightsidefp.co.uk.

Your personal data will also be stored in the website’s database. Your data is encrypted with the Gravity Forms Encrypted Fields plugin before it is saved to the database. It is saved in the website database so we can record your consent when subscribing to the mailing list. Your contact form data saved in the website database will automatically be deleted 1 year after submission.

Change of Ownership

Information about users and visitors, including personal data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User or visitor data commits to a privacy notice that has terms substantially consistent with this privacy notice.

Client data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the client data commits to a privacy notice that has terms substantially consistent with this privacy notice.

Links to Other Web Sites

This privacy notice does not cover the links within this site linking to other websites. Those sites are not governed by this privacy notice, and if you have questions about how a site uses your information, you’ll need to check that site’s privacy statement.

Cookies

Cookies are small text files that store information on your hard drive or browser which means that we can recognise that you have visited our website.

They make it easier for you to maintain your preferences on our website.

A cookie often includes a randomly generated number which is stored on your device. Many cookies are automatically deleted after you finish using the website.

Use of Cookes

This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission.

Any cookies that may be used on this website are used either solely on a per session basis or to maintain user preferences. Cookies are not shared with any third parties.

Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third-party cookies. For example, in Chrome, you can block or allow all cookies by default. On your computer, open Chrome. At the top right, click ‘More Settings’, then under 'Privacy and security', click Cookies and other site data and select an option.

Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one.

Types of cookies that may be used during your visit to the website are listed below:

Cookie NameExpirationWhat It Does
_ga2 yearsUsed to distinguish unique users by assigning a randomly generated number as a client identifier
_gid24 hoursUsed to distinguish users.
_gat1 MinuteUsed to throttle request rate. More info.
privacy_embeds30 DaysUsed to manage third party content

Third Party Embeds

The below section lets you control the privacy settings for third-party embeds on this site. We provide you with the choice to accept these third party embeds or not. The checkboxes below show you all the embeds you have consented to so far. You can opt-out any time by un-checking them and clicking the update button.

Changes to this Privacy Notice

We keep our privacy notice under regular review. This privacy notice was last updated on 27/01/21.

How to contact us about your personal data or this privacy notice

If you have any questions about this privacy notice or about your personal data, please email us at hello@lightsidefp.co.uk or write to us at the following address: Data Enquiries, LightSide Financial Planning, 1st Floor, 73 Liverpool Road, Crosby, Merseyside, L23 5SE.

The data controller is SMC Financial Services Limited, Registration Number ZA233564.