This is the Privacy Notice of Bespoke Independent Financial Advisers Limited, registered in England no. 08733808, whose registered office is Dorna House Two, Guildford Road, West End, Surrey GU24 9PW referred to as we, us or our in this Privacy Notice.
This Privacy Notice sets out how we collect and process your personal data, provides certain information that is legally required, and also lists your rights in relation to your personal data, and relates to:
1. Provision of services and advice or to provide you with the information, products and services you have requested from us.
2. Services include, but are not limited to, financial, retirement and protection planning and include policies and accounts associated with the provision of such planning.
3. Compliance with regulation and legislation in relation to anti-money laundering regulation and the Financial Services & Markets Act.
This Privacy Notice relates to personal information that identifies you as a natural person (whether you are an actual or potential customer, an individual who browses our website or an individual outside our organisation with whom we interact). We refer to this information throughout this Privacy Notice as personal data or personal information and further detail of what this includes is set out in this Privacy Notice below.
The privacy and security of your personal information is very important to us, so we want to assure you that your information will be properly managed and protected by us at all times. Please read this Privacy Notice carefully as it explains how we may collect and use your personal data.
This Privacy Notice may vary from time to time so please check it regularly. This Privacy Notice was last updated on 28 February 2023.
How to Contact Us
For the purposes of relevant data protection legislation, we are a controller of your personal data. As a controller, we use (or process) the personal data we hold about you in accordance with this Privacy Notice.
If you need to contact us in connection with the use or processing of your personal data, then you can do so using our contact details as set out below.
Data Protection Officer
Our Data Protection Officer is Liam Walter who you can contact at:
Dorna House Two
Guildford Road
West End
Surrey GU24 9PW
Telephone – 01483 766656
Email: liam.walter@bespokeifa.co.uk
What Information We Hold About You and Where We Obtain This From
The personal data that we collect about you may include the following information:
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- Personal data you provide to us in person, via our website or by telephone
- Personal data you provide when you enquire about our services or when you engage in services with us
- General information about you, such as your name, address, contact details and date of birth
- Personal data you provide if you subscribe to any of our mailing or newsletter services
- Your claims and credit history
- Financial details, such as your bank account and card details
- Criminal convictions
- Information about your use of our website such as your IP address, which is a unique number identifying your computer, including personal data gathered using cookies
In addition, we may obtain certain special categories of your data (special categories of data) and data about criminal convictions, and this Privacy Notice specifically sets out how we may process these types of personal data. The special categories of data are data concerning health.
We collect your personal data from you as a controller when we obtain/provide quotations for services, when we initiate services for you and when we make amendments to the services we provide for you. This may also involve the collection of data from or about others who are associated with your services, such as other persons insured on your policies or your employees or representatives. By giving us information about someone else for the purpose of arranging services for them either jointly or on a sole basis, you confirm that you have their permission to do so and that you have shared this Privacy Notice with them.
By asking us to arrange services for you where this involves passing information to us relating to children, you confirm to us that in doing so you are the responsible guardian of the child.
We also collect information from publicly available sources and third party databases made available to the insurance and finance industry for the purposes of reducing fraud and financial crime as well as any other third party databases where your personal data may be held, provided such third parties have lawful bases on which to share such personal data with us.
How We Use Your Personal Data and The Lawful Basis For Doing So
Where we are relying on a basis other than consent
We may rely on one or more of the following legal bases when processing your personal data for the following purposes:
| Purposes for which we process your personal data | The basis on which we can do this (this is what the law allows) |
| In order to perform our contractual obligations to you. This would include our fulfilling your requests for services both when initiated and ongoing | The processing is necessary in connection with any contract that you may enter into with us |
| To administer your account, including financial transactions | The processing is necessary in connection with any contract that you may enter into with us |
| To assist in the prevention and reduction of fraud and other financial crime | The processing is necessary for us to comply with the law and our legal requirements |
| In the interests of security and to improve our service, telephone calls you make to us may be monitored and/or recorded | The processing is necessary to pursue our legitimate interest in the management and operation of our business |
| To let you know about similar products and services that may be of interest to you | The processing is necessary to pursue our legitimate interest in operating our business |
| To make automated decisions, automated profiling and fraud detection | The processing is necessary in connection with some contracts that you may enter into with us |
Special categories of data and criminal convictions
We may also need to collect special categories of data from you such as information about your health, personal data revealing racial or ethnic origin, religious or philosophical beliefs or trade union membership and generic data. We may also collect information on criminal convictions which we may share with third parties. The lawful basis on which we can do this, is the processing for reasons of substantial public interest relating to the services provided by us.
Who We Pass Your Personal Data To
We may need to pass your personal data to other companies which may include:
- The insurers, intermediaries, product providers and third party service providers that we use for the purpose of arranging and administering your services
- Firms that provide administration and processing services to us or on our behalf under contract in order to complete activities such as IT systems and administrative services and other activities set out in this Privacy Notice, as well as support activities such as finance and auditing services
- Organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies
- Other organisations where we have a duty, or are permitted, to disclose your personal information by law, for example if we received a valid request from the police or other third party organisation in the interest of preventing and detecting crime
- Fraud prevention agencies and operators of registers available to the finance or insurance industry to check information and prevent fraud
- Credit reference agencies to check your credit history where applicable. This check will be recorded on your credit reference file without affecting your ability to apply for credit or other financial products
- Another company, if our business or part of it is bought or taken over by that company to make sure your services can continue to be serviced or as part of preliminary discussions with that company about a possible sale or take over
The information you share with us may be transferred by us or any of the types of firms or organisations we have noted above, to other countries in order for processing to take place, including locations outside of the UK. We will only do so if there are adequate levels of protection in place as required by applicable data protection laws.
Accessing Our Website and Cookies
When you visit our website, we may collect information from you such as your email address, IP address and other online identifiers. This helps us to track unique visits and monitor patterns of customer website traffic, such as who visits and why they visit. We may use third parties to collate IP addresses to help us understand our internet traffic data and data regarding your browser type and computer. We may also use web usage information to create statistical data regarding the use of our website. We may then use or disclose that statistical data to others for marketing and strategic development purposes, but no individuals will be identified in such statistical data.
We may use cookies and/or pixel tags on some pages of our website. A cookie is a small text file sent to your computer, mobile phone or tablet depending on the device used to access our website. A pixel tag is an invisible tag placed on certain pages of our website, but not on your computer. Pixel tags usually work together with cookies to help us give you a more tailored service. We may also use cookies and pixel tags in our email communication to personalise the email and track whether the email has been opened and whether the recipient has used any website links contained in the email communication. This allows us to monitor and improve our email communications and website. Useful information about cookies, including how to remove them, can be found at http://allaboutcookies.org.
Internet browsers normally accept cookies by default, although it’s possible to set a browser to reject cookies. However, refusing to accept cookies may restrict your use of our website and/or delay, or affect the way in which our website operates. You can find more information on cookies when you visit our website.
The open nature of the internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended. While this is outside of our control, we do take the protection of your information very seriously and aim to apply appropriate levels of security at all times.
Closed Circuit Television (CCTV)
Where CCTV is used, we have identified and documented the potential impact on an individual’s privacy and have taken this into account when installing and operating the CCTV system. We regularly review whether CCTV is still the best security solution.
We will clearly inform individuals of our use of CCTV, and we only retain recorded CCTV images for long enough to allow for any incident to come to light (e.g., for a theft to be noticed) and to investigate it. We will respond to individuals or organizations making requests for copies of their images on our CCTV footage and will seek prompt advice from the Information Commissioner where there is any uncertainty. We securely store CCTV images, limit access to authorised individuals and regularly check that the CCTV system is working correctly. We have a nominated individual who is responsible for the operation of the CCTV system.
Telephone Recording
Where telephone conversations are recorded, we will inform you of this at the beginning of the call together with our reasons for doing so and any objections should be raised immediately. Telephone recordings will be stored securely, and in accordance with best practice as suggested by the financial regulator and you have the right to request a copy where this is still available. The call recordings will only be passed to third parties where we have a legal right or legal obligation to do so. Payment card data is protected in accordance with the Payment Card Industry Data Security Standard (PCI DSS) and our system prevents us from recording Sensitive Authentication Data (SAD) or where this is not possible, is immediately deleted after card authorisation.
Your Rights
We will only store your data for as long as is necessary to comply with the requirements of your services and any legal obligations or lawful processing conditions that may exist as a result. You have a number of rights concerning the personal information we use, which you may ask us to observe. In some cases, even when you make a request concerning your personal information, we may not be required, or be able to carry out your request as this may result in us not being able to fulfil our legal and regulatory obligations under the lawful processing conditions under which we hold your data or because there is a minimum statutory period of time for which we have to keep your information. If this is the case, we will let you know our reasons.
You can ask us to:
- Provide a copy of your personal information
- Correct or delete unnecessary or inaccurate personal information
- Restrict or object to the use of your personal information at any time
- Object to any automated decision, including profiling which may have been used by third party service providers, such as insurance providers. Where an automated decision has been made, we will advise you of this and of your rights
- Provide your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller. This right only applies where our processing of your personal data is automated, and the processing took place initially with your consent or for the performance of a contract with you
- Where we rely on your consent to use your personal information, you can withdraw that consent at any time. Where your consent is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing material has been sent prior to you advising that you don’t want us to contact you again
If you have any questions or concerns about this Privacy Notice or your data protection rights, please contact us using our details set out at the beginning of this Privacy Notice.
You also have the right to make an enquiry or to complain to the Information Commissioner’s Office (ICO) if you are unhappy with our use of your data, or if you think we have breached a legal requirement. Further details about the ICO are available at: www.ico.org.uk.
How We Contact You About Other Products and Services
We may from time to time process your personal data to let you know about similar products and services that may be of interest to you. This is because we value your custom, and we pride ourselves in offering professional and tailored advice which meets your specific service needs. This includes keeping you informed on the latest finance industry information relating to the services we provide to you. Our lawful basis for processing your personal data in this way is necessary to pursue the legitimate interests of our business, unless we have otherwise obtained your consent to do so. We may contact you by post, telephone or e-mail. You will be given the option to stop receiving any communications from us in this regard at any time however please note that this will not affect us contacting you about the servicing of products that you have specifically requested from us.