We have a legal duty to protect the privacy of all personal and business data obtained from you while you are using this website.
Some web usage and technical information is collected by this website to help us improve our service to you, but this does not contain any personal data.
We receive and store a range of website usage information whenever you use this website. We use this to:
– Assess the effectiveness of marketing campaigns.
– Develop and deliver services and information that better meet your needs.
The type of website usage information that we collect during your visits to our site includes, for example, the date and time, pages viewed or searched for. We may also use web usage information to create statistical data regarding the use of our website, however, no individual identities will or can be identified in such statistical data.
Desire Wealth is not responsible for the content on external websites that are linked to / from our site. We do not link to external sites in return for cash, services or any other payment in kind – links are selected purely based on the relevance of their content for our audience.
The internet and use of e-mail are not secure and by using these methods to communicate with us you accept that there are risks associated with sending information via this method.
Cookies are small pieces of data given to your browser by a website which may be stored as text files in the cookie directory of your computer. Cookies are not programs and cannot collect information from your computer. They do not damage your computer and are defined as "a piece of text stored on a user's computer by their web browser. A cookie can be used for authentication, storing site preferences, shopping cart contents, the identifier for a server-based session, or anything else that can be accomplished through storing text data" (source: Wikipedia, 2011).
Each website may send cookie data to your browser which may save it if your browser's preferences allow it to do so. To protect your privacy your browser only returns a cookie to the website that sent you the cookie and does not send it to any other website. A website cannot access your cookie directory or information on your computer, instead relevant cookies are included by your browser within each request you make to the website. A website can only obtain cookie data that your browser sends to it.
The majority of browsers allow you to control cookies through the browser’s settings. For more information about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org or to opt out of being tracked by Google Analytics across all websites, visit tools.google.com/dlpage/gaoptout.
_utma, _utmb, _utmc and _utmz – used for our Google Analytics for us to measure how visitors use our site, all information is completely anonymous and we cannot track who the user is. _utmc is a temporary cookie and is deleted once your browser is shut.
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 or 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 and Financial requirements your Personal Data may include: Title, names, 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 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 and Financial 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 needs, 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 providers in relation to insurance products that may meet your needs and to provide you with advice and/or 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 your investments and finances. 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 electronic ID checks, we would not require your consent. In the event that we do need to confirm your ID we use SmartSearch™, an online provider of Anti Money Laundering Services who verify UK Individuals by confirming name, address and date of birth i.e. you are who you say you are. 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, and on our computer systems (websites, email 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 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 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 and Financial Product 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 and Product specialists (in each case where we believe this to be required due to your particular circumstances or needs). 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, pension 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. 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. Our online client portal offers secure messaging and document sharing as well as the added benefit of giving you access to your portfolio and up to date valuations. Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely. 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); while we will do our best to act on your preferences as soon as we reasonably can, please be aware that it may take up to 14 days for changes to your preferences concerning Service Messages to take effect. Please note that emails which notify you of changes to our Client Agreement, Service Proposition and Terms of Engagement, or to policies we apply under our Terms of Engagement, are unaffected by your preferences for newsletters and Service Messages. 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: Louise Fox (Director) Thremhall Park, Start Hill, Bishops Stortford, Herts, CM22 7WE
Tel: 01279 215585
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.