Privacy Notice
Introduction
This notice provides you with information concerning our collection and use of personal data. If you have any queries regarding this statement, please do not hesitate to contact us.
Legal Basis
We collect, control and process your personal information because this is necessary to provide you with information, answer any queries you may have and for the provision of our services to you.
Contractual necessity is therefore the lawful basis for collecting, controlling, and processing your personal details and those of your employees and service providers other than sensitive or special category personal data for which we require individual consent unless we are processing for insurance underwriting purposes or employment purposes.
Sensitive or special category personal data includes:
-
Racial or ethnic origin
-
Political opinions
-
Religious or philosophical beliefs
-
Trade union membership
-
Genetic data
-
Biometric data
-
Data concerning health
-
Data concerning sex life or sexual orientation
We would discuss with you the need for the provision of sensitive data before you provide this information. The subsequent provision of sensitive personal data will be taken as consent to this processing.
We would discuss with you the need for the provision of sensitive data before you provide this information. The subsequent provision of sensitive personal data will be taken as consent to this processing.
Where you have disclosed sensitive personal data about a client, we will assume that you have obtained informed consent to such sharing.
It is entirely up to you as to whether or not you choose to provide us with any personal information. If you choose not to, we simply may not be able to assist you.
We do not use your personal data for marketing purposes nor will we share your data with any other organisation for marketing purposes.
What Data We Collect & What Do We Do With It
Completing our initial enquiry form
If you contact us via the web form on our website your data will be protected by a secure socket layer. This site is hosted at Wix.com.We use a standard Wix service to collect anonymous information about users' activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help to improve it. For more information about how Wix processes data, please see Wix’s privacy notice. If you enter details into our webform these will be transmitted to us via email and temporarily stored within the Microsoft 365 hosted environment. The site is secured by Wix.
Calling Our Business Line
We use a hosted Voice over IP system and any answerphone messages you leave will be stored within the hosted Microsoft 365 system. Calls may be recorded for training and quality purposes and will be stored within the same system.
Doing Business With Us
In order to communicate with you about our services we will require your contact details including personal email addresses. Your name and email and information relating to the work we undertake for you will be stored on our encrypted devices.
Client Bulletins & Updates
We will store your name and email address with a data processor to enable us to communicate regulatory and service updates to you. You will have the option to opt out of any regular communications.
All Services
We collect and use information about you, which will include personal data in order for us to advise you and make arrangements for you.
Sharing Your Data
In order to fulfill our obligations under any contract for services we will need to share your data with third party Data Controllers and Data Processors.
Data Controllers
This will include:
-
Product & service providers in relation to investments, plans and pensions.
-
Our compliance monitoring services.
-
The Financial Conduct Authority.
-
The Financial Ombudsman Service.
-
Any other regulators where so required.
-
Para-planning (investment research) services.
We also use external Data Processors that will hold information for the following purposes:
-
Secure file sharing
-
Data backup
-
Dissemination of information
All external processors are only permitted to process your data in line with our instructions.
We ensure that the contract terms with our processors meet the requirements of UK data protection law.
​
Automatic - Wix website hosting processes your IP address and used cookies to enhance your experience.
​
Microsoft - We use the Micosoft 365 hosted environment. It provides our email hosting and data storage. Personal data is processed for calendar, contact and email communication. SharePoint and One Drive secure file sharing is used in conjunction with other Microsoft 365 software where we may process your personal data.
Dropbox - Securely sharing files and documents that contain or may contain personal data pertinent to the work we undertake for clients and for our staff.
Wealthbox - Keep records of work we do for you, your plans, transactions and personal details and financial information.
​
Cashcalc - Securely sharing files and documents that contain or may contain personal data pertinent to the work we undertake for clients and for our staff.
​
FE Analytics - Investment fund analysis and research, only names are held.
​
Selectapension - Research and analysis of pension products, names and birth dates may be held.
​
Voyant - Cash flow modeling, names and financial information are processed.
​
Myregdata - Accounting software for record keeping and invoicing. Contact information is processed.
Whatsapp - For secure communication and sharing of data
​
Loom - For video recording and communication
​
Mailchimp - For client communications and marketing
In all cases we seek to minimize the amount of personal data shared and in some cases anonymize this. It is essential, however, that we can identify you quickly and easily so information shared may be identifiable as your personal data.
We will not share your personal information in any other circumstances than those necessary for the provision of service to you or where we are required to do so by law.
Otherwise, we will not share your personal information with other companies without your express authority except if the firm is sold or where we are required to do so by law.
Marketing
The information we collect about you is used solely for the purposes for which it was provided. We will never use your data or share it for marketing purposes.
Your Rights
Under data protection law you have the right to ask us for a copy of the information we hold about you, and to have any inaccuracies corrected or removed. You may also ask us to delete all personal data held by us or any controller or processor with which we have shared your data.
To do this, please either contact us in writing, by telephone or email.
Contact
For any queries about data protection please contact:
Contact name
James de Lisle Wells
de Lisle Financial Planning Ltd
4 The Apple Store, Far Peak, Gloucestershire GL54 3JL
Telephone
01285 707111
Web
Where We Store Your Personal Data
All the data that we collect is stored within the encrypted Microsoft 365 environment, synchronized to our encrypted computers, off-site encrypted backup storage in the UK, or with our listed processors under contract within the EU.
IP Addresses and Cookies
Our website uses cookies purely to enhance your experience.
(A cookie is a piece of information that is stored on your computer's hard drive which records how you have used a website. This means that when you go back to that website, it can give you tailored options based on the information it has stored about your last visit.)
Vital Cookies
Ones that are essential to the operation of the website. These cookies enable a site to remember text entered in a page within the same session or to remember whether a user is logged in or not, the site cannot function without them.
Performance Cookies
Performance cookies, which collect information about website usage to enhance the web experience. Examples of these include website analytics (i.e. Google Analytics) and ad-response rates (where data is collected exclusively for calculating click-through rates). They don’t collect information that can identify a particular visitor. These cookies are usually persistent and have fairly long expiry rates.
Functionality Cookies
These remember the choices that users make within a web page, such as usernames, language or region to provide an enhanced, more personalised web experience. They cannot track your activity on other websites and are anonymous.
Advertising Cookies
Targeting or advertising cookies collect information about your browsing habits to tailor third-party advertising to meet your interests. They are usually placed by advertisers with website operators’ permission. We do not use this type of cookie.
Any changes we may make to our privacy policy in the future will be posted on our websites where appropriate or may be notified to you by post or e-mail.