Article I. Introduction
- We will not send you unsolicited emails or communication (spam) - correspondence will be limited to follow-up emails relating to your Wealth Personality® report and/or other profiling tools which we provide;
- We will employ industry standard levels of security in data storage to protect you;
- We will collect and process your personal data in accordance with the terms of the applicable data protection law; and
- We employ a number of cookies to enhance your user experience during a session
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. They are widely used in order to make websites work, or work more efficiently, and to provide information to the owners of the website.
Below you will find a list of the cookies we are currently employing and our rationale for employing them in the first place.
These are cookies that are required for the operation of our website.
- Session: this is for basic features and functionality, and will be stored on your machine for the duration of the session of use of the website.
- Anti forgery: this is used to prevent CSRF (Cross-Site Request Forgery) attacks, and will be stored on your machine for the duration of the session of use of the website.
- ARRAffinity/ARRAffinitySameSite - Used to protect the functionality of your session.
Namely, (a) analytical or performance cookies (which allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily); (b) functionality cookies (which are used to recognise you when you return to our website and remember your preferences); and (c) Targeting cookies (which record your visit to our website, the pages you have visited and the links you have followed. . We will use this information to make our website and the advertising displayed on it more relevant to your interests.
- Google reCAPTCHA: this is a Google reCAPTCHA cookie which is used to provide an additional layer of security when using this website and will expire six months after the session of use of the website.
- Tracking: this is a Google Analytics cookie which is used to track user interaction and demographics, and will expire two years after the session of use of the website.
Aside from the third party advisors and institutions who offer our products and services to their customers, we do not share the information collected by the cookies with any third parties.
Article III. What data are we collecting about you?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, title, date of birth and age.
- Contact Data includes email address and postal address.
- Transaction Data includes details about products and services you have or are looking to procure from us.
- Technical Data includes internet protocol (IP) address, browser type and version, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing (whether from us or our third parties) and your communication preferences.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to, and use of, the WealthPersonality® product). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Article IV. How is your data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Transaction and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- access and use our products or services
- subscribe to our service or publications
- submit a referral request on our website; or
- give us feedback or contact us.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
Contact and Transaction Data from providers of technical services.
- Identity and Contact Data from third party advisors, institutions, data brokers or aggregators.
- Identity and Contact Data from publicly available sources (such as the Electoral Roll or Companies House).
Article V. What are we doing with this information?
We will only use your personal data when the law allows us to. Generally we are processing your data for the following purposes
- Where we need to comply with law's and regulations(including UK data protection law) that we are subject to;
- Where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract; and/or
Where it is necessary for the purposes of our legitimate business interests (or those of a third party) and your interests
and fundamental rights do not override those interests, thereby allowing us to:
- Provide you with your Wealth Personality® insights;
- Ensure our website is tailored for the best user experience for you;
- To notify you of changes to our service and polices;
- To improve customer service; and
- To personalise your experience.
For the avoidance of doubt, ‘legitimate interest’ means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the details set out in Article VII (Contacting Us) below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the using the details set out in Article VII (Contacting Us) below if you need further information about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis of processing including basis of legitimate interest|
|To register you as a new user of the products/services||
|Performance of a contract with you.|
|To process and deliver the products/services to you.||
(d) Marketing and Communications
|Performance of a contract with you.|
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey.
(c) Marketing and Communications
(a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services, to develop the products/services and to grow our business).
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation.
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.||
(d) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.||
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).|
|To make suggestions and recommendations to you about goods or services that may be of interest to you, including other behavioural tools we offer.||
(e) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business).|
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and services may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or procured products or services from us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us using the details set out in Article VII (Contacting Us) below. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of product/service usage or other transactions.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is explicit consent compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details set out in Article VII (Contacting Us) below.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with third parties for the purposes set out below in the first paragraph of this Article:
- Third party advisors, who have contracted with us to provide Wealth Personality® services to their clients on their behalf.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see Article VI (What are your rights?) below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Article VI. What are your rights?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We will comply with any requests to exercise your rights in accordance with applicable law. Should you need any of this information, or if you have any questions or concerns regarding your personal information, you should contact us using the contact details outlined below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Article VII. Contacting Us
Full name of legal entity: Behavioural Finance Ltd
Email address: William Cowie – email@example.com
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Article VIII. Certifications