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Privacy policy

Privacy policy

This policy explains how we use personal information we collect about you.

We keep our privacy policy under regular review and share important updates on our website.

We last reviewed this policy in August 2023. If there are major changes to the policy, we may contact you to let you know.

Our website contains links to other websites. This policy only applies to this website. When you link to other websites you should read their own privacy policies.

Our contact details

Please contact us if you have any questions about our privacy policy or information we hold about you:

  • By post: Willis Owen Limited, PO Box 766, BOREHAMWOOD, WD6 9JS
  • By phone: Telephone 0800 597 2525 (from overseas 020 8236 1240)
  • By email: enquiries@willisowen.co.uk

The type of personal information we collect

We currently collect and process the following information:

  1. Details about who you are. This includes your name, address, date of birth, email address, nationality and gender
  2. Information we need to provide products or services to you. This includes your residency status, bank details, telephone number(s) and National Insurance number
  3. Data which allows you to access our online services or our contact centre. This includes your email address, phone number, any usernames and passwords
  4. Details used to verify your identity. For example details relating to your passport
  5. Sensitive personal data relating to your health or medical conditions
  6. Information we collect automatically when you visit our website. This includes your Internet Protocol address (or IP address), geographic location, the web browser you are using, and your operating system. We may also collect information on the full click path you use while on our site. For further details see the ‘cookies’ section below
  7. Information collected automatically when we send emails to you. This includes whether you have opened an email and, if so, the device and any web browser used
  8. Information about your contact with us. For example from telephone conversations and recordings or other forms of correspondence
  9. Information about you which we receive from certain third parties.

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • To complete an application to use one or more of our online services
  • To use our online services or interact with us via social media
  • To contact us via telephone
  • To contact us using email, secure messages, live chat or by letter
  • To participate in surveys to help us understand you better and improve our products and services
  • To enter competitions
  • To request literature or marketing emails.

We also collect personal information about you indirectly from commercially or publicly available sources. We do this for example to verify your identity, check the accuracy of information we hold about you or to get new contact information if we have lost touch with you.

We might also receive information about you from someone else who is acting for you. This could include, for example, a power of attorney or legal representative or another financial services provider.

We use the information that you have given us to:

  1. Process your application, manage your account and, if you agree, to email you about other products and services we think may be of interest to you
  2. Tailor our products and services to better account for any special circumstances or needs you may have. With your consent, sensitive personal information such as that relating to your health, may be used for this purpose
  3. Provide personal information to other companies we have chosen to support us in providing the products and services we offer to you
  4. Interact with companies who can help us in our contact with you. For example those who may help us to validate your contact details. We will not share your information for marketing purposes with other companies
  5. Carry out identity checks. We may send your details to, and use information from identity verification, credit reference and fraud prevention agencies
  6. Process an application when you are acting for someone else. This could be under a power of attorney for example. In this case we will also use the information given to us about the account holder. This could include any information we may have been given about the status of their health
  7. Train our staff, so we can ensure appropriate security or to help us in the ongoing management of your products and services. We may use call recordings for this purpose
  8. Send you information about products and services which may be of interest to you. We will only do this with your consent. You can choose which types of products, services or information you would like us to share with you.

Who we may share your information with:

  1. Companies we work with to deliver the products and services we offer. This includes selected research, consultancy or technology companies
  2. Selected third parties which we think may be of benefit or interest to you. We will only do this with your consent
  3. Companies you ask to share your data with
  4. Credit reference agencies
  5. Fraud prevention agencies
  6. Identity verification agencies
  7. HM Revenue & Customs
  8. UK regulatory bodies, such as the Financial Conduct Authority and the Information Commissioner’s Office
  9. Organisations that introduce you to us
  10. The UK Financial Services Compensation Scheme
  11. The Financial Ombudsman Service
  12. Law enforcement and other agencies who support us in the detection and prevention of crime.

Our legal basis for using your information

The UK General Data Protection Regulation (UK GDPR) sets out the lawful bases for the processing of personal data. The lawful basis we rely on for collecting and using your personal information depends on the type of information and how and when we collect it.

The following lawful bases will apply to our processing of your personal data:

  1. Where processing is necessary for the performance of a contract you have with us. If you wish to register for our online services or use a product for example, we need some personal information including your name, address, phone number, date of birth and bank details
  2. Where the processing is necessary for us to meet a legal obligation, such as information which is required by law to open or operate an investment product. This could include, for example, the collection of your National Insurance Number
  3. Where you have given us your consent for us to process your personal data for a specific purpose. This could be for the purpose of receiving marketing material or for processing special category data. Special category data can include information about your state of health. You may withdraw your consent at any time and for details of how to do so, see below.
  4. Where the processing is in the legitimate interests of Willis Owen i.e.
    • To deliver appropriate information and guidance. This could include making you aware of options that can help you use our products and services
    • To make you aware of enhancements to our online services which we may make available
    • Where we need to process your information to better understand you and your needs. We do this so we can send you more relevant communications about the products and services we provide to you
    • To develop new products and services and tailor existing products and services
    • To conduct research and collect information to improve the products and services we offer.

Where we rely on the 'legitimate interests' basis for processing your data, we will carry out an assessment to ensure that this use of your personal information is not excessive, unnecessary or unduly intrusive.

Consent

Where you have given us your consent to send you marketing material, you have the right to withdraw your consent at any time. Such material might include information relating to investment markets, personal investing insights or about other products and services offered by Willis Owen or our selected third parties.

You may also withdraw your consent to our processing of any ‘special category’ data we may collect or hold about you.

If you wish to withdraw your consent for our use of your data in this way, please contact us. You can also change your marketing consent options using the ‘my profile’ section of the website.

How we store your personal information

We will keep all data for as long as necessary for the purpose it was collected for. In so doing we will consider any potential legal claims as well as any legal and regulatory requirements.

Even when you no longer have a relationship with us, we are required to keep information for different legal and regulatory reasons. The length of time will vary but we will ensure we are only keeping data for no longer than necessary.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You can ask us for copies of your personal information.

Your right to rectification- You can ask us to correct personal information you think is not correct. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You can ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You can ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You can object to the processing of your personal information in certain circumstances.

Your right to data portability - You can ask us to transfer personal information we hold to another organisation, or to you, in certain circumstances.

If you wish to make a request, please contact us. You can use any of the methods detailed in our ‘Our contact details’ section.

We will consider all requests and will respond within one month unless your request is complex or we have received a number of requests from you. In such cases the response period may be extended by up to a further two months.

We will not charge a fee for processing your request but a reasonable administration fee may be charged if:

  • Your request is clearly and obviously unfounded, malicious or excessive; or
  • You request further copies of your data following a previous request.

By law we can withhold certain information when dealing with requests for copies of your personal data. This can include data relating to financial crime or information relating to legal advice or proceedings. We will let you know if we are lawfully withholding any information when we respond to your request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint. You can use any of the contact methods detailed in the ‘Our contact details’ section.

You can also Complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

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