Our Privacy Notice

How your personal information is used by us

Last updated April 2018

Your information will be held by Wellington Wealth (Glasgow) Limited

How we use your personal information

This privacy notice is to let you know how we promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

Our Privacy Promise

We promise:

· To keep your data safe and private.

· Not to sell your data.

· To give you ways to manage and review your marketing choices at any time.

Data Protection law will change on 25 May 2018.

This notice sets out most of your rights under the new laws. We will keep this notice up to date on our website www.wellington-wealth.com

Who we are

Wellington Wealth (Glasgow) Limited is a firm of independent financial advisers.

You can find out more about us at https://www.wellington-wealth.com/trusted-advice/

If you have any questions, or want more details about how we use your personal information, you can ask us using our secure online contact form.

Or you can call us on 0141 221 3222.

How the law protects you

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside Wellington Wealth (Glasgow) Limited. The law says we must have one or more of these reasons:

· To fulfil a contract we have with you, or

· When it is our legal duty, or

· When it is in our legitimate interest, or

· When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

What we use personal information for

What we use your personal information for	Our Reasons	Our Legitimate interests
• To manage our relationship with you • To develop new ways to meet our customers’ needs and to grow our business. • To develop and carry out marketing activities. • To study how our customers use products and services from us and other organisations. • To provide advice or guidance about products and services.	• Your consent. • Fulfilling contracts. • Our legitimate interests. • Our legal duty.	• Keeping our records up to date, working out which of our products and services may interest you and telling you about them. • Developing products and services, and what we charge for them. • Defining types of customers for new products or services. • Seeking your consent when we need it to contact you. • Being efficient about how we fulfil our legal duties
• To develop and manage our brands, products and services. • To manage how we work with other companies that provide services to us and our customers.	• Fulfilling contracts. • Our legitimate interests. • Our legal duty.	• Developing products and services, and what we charge for them. • Defining types of customers for new products or services. • Being efficient about how we fulfil our legal and contractual duties.
• To deliver our products and services. • To manage customer payments. • To manage fees & charges. • To collect and recover money that is owed to us.	• Fulfilling contracts. • Our legitimate interests. • Our legal duty.	• Being efficient about how we fulfil our legal and contractual duties. • Complying with regulations that apply to us.
• To detect, investigate, report, and seek to prevent financial crime. • To manage risk for us and our customers. • To obey laws and regulations that apply to us. • To respond to complaints and seek to resolve them.	• Fulfilling contracts. • Our legitimate interests. • Our legal duty.	• Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect . • Complying with regulations that apply to us. • Being efficient about how we fulfil our legal and contractual duties.
• To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit.	• Our legitimate interests. • Our legal duty.	• Complying with regulations that apply to us. • Being efficient about how we fulfil our legal and contractual duties.
• To exercise our rights set out in agreements or contracts.	• Fulfilling contracts.	• Being efficient about how we fulfil our legal and contractual duties.

Groups of Personal Data

We use many different kinds of personal information, and group them together like this.

Type of Personal Data	Description
Financial	Your financial position, status and history.
Contact	Where you live and how to contact you.
Demographic	This includes details about your work or profession, nationality, education and where you fit into general social or income groupings.
Transactional	Details about payments to and from your accounts
Contractual	Details about the services or products we provide to you.
Communications	What we learn about you from letters, emails, and conversations between us.
Social Relationships	Your family, friends, and other relationships.
Open Data and Public Records	Details about you that are in public records such as the Electoral Register, and information about you that is openly available on the internet.
Documentary Data	Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence, or birth certificate. National Identifier, a number or code given to you by a government to identify who you are, such as a National Insurance number.
Special types of data	The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so: o Racial or ethnic origin o Religious or philosophical beliefs o Trade union membership o Genetic and bio-metric data o Health data including gender o Criminal convictions and offences
Consents	Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you, whether you get paper statements, or electronic valuations.

Where do we collect personal information from

We need to gather data directly from you to satisfy our legal obligations, you will provide this information:

· When you make an appointment

· At our first meeting

· When you engage our services

· When you talk to us on the phone or in the office

· When you use our website or mobile device app

· In emails letters & forms

· In financial reviews and review meetings

· In customer surveys

· If you take part in our events, promotions or competitions we may hold

We may collect personal information about you (or your business) from other companies such as pension, investment & protection providers using a letter of authority signed by you, giving your consent for us to do this. The information is required to provide you with complete and accurate financial advice.

Data from third parties we work with:

· Companies that introduce you to us

· Solicitors

· Accountants

· Mortgage Providers

· Other Financial advisers

· Insurers

· Social networks

· Fraud prevention agencies

· Payroll service providers

· Public information sources such as Companies House

· Medical practitioners*

· Government and law enforcement agencies.

* For some insurance products, we may ask your GP or other medical professional to send us a report. We will only do this if we get your consent first.

Who do we share personal information with

We may need to share your personal information with the following organisations

· Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business

· HM Revenue & Customs, regulators and other authorities

· Financial Conduct Authority

· UK Financial Services Compensation Scheme

· Financial Ombudsman Service

· Fraud prevention agencies

· Any party linked with you or your business’s product or service

· Companies we have a joint venture or agreement to co-operate with such as auditors

· Organisations that introduce you to us

· Companies that we introduce you to

· Companies you ask us to share your data with.

We may need to share your personal information with other organisations to provide you with the product or service you have chosen:

· If you use direct debits, we will share your data with the Direct Debit scheme.

· If you apply for protection through us, we may pass your personal or business details to the insurer, and onto any reinsurers.

· If you make an insurance claim, information you give to us or the insurer may be put on a register of claims. This will be shared with other insurers.

We may also share your personal information if the make-up of Wellington Wealth (Glasgow) Limited changes in the future:

· We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.

· During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.

· If this change happens, then other parties may use your data in the same way as set out in this notice.

How we use your information to make automated decisions

Occasionally use systems to make automated decisions based on personal information we have – or are allowed to collect from others – about you. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them.

Here are the types of automated decision we make:

Pricing

We may decide what to charge for some products and services based on what we know.

Tailoring our services

We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them.

Detecting fraud

We use your personal information to help decide if your personal or business accounts may be being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them.

Engaging our services

When you engage our services, we check that the product or service is relevant for you, based on what we know. We also check that you meet the conditions needed to provide financial advice. This may include checking age, residency, nationality or financial position.

Your rights

As a person you have rights over automated decisions.

· You can ask that we do not make our decision based on the automated score alone.

· You can object to an automated decision, and ask that a person reviews it.

If you want to know more about these rights, please contact us.

Fraud Prevention Agencies (FPAs)

We may need to confirm your identity before we provide products or services to you or your business. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We may use Fraud Prevention Agencies to help us with this.

Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.

A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for you.

We will use the information to:

· Confirm identities

· Help prevent fraud and money-laundering

· Fulfil any contracts you or your business has with us.

We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.

FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.

The information we use

These are some of the kinds of personal information that we use:

· Name

· Date of birth

· Residential address

· History of where you have lived

· Contact details, such as email addresses and phone numbers

· Financial data

· Data relating to your or your businesses products or services

· Employment details

· Vehicle details

· Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address.

Automated decisions for fraud prevention

The information we have for you or your business is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We and FPAs may process your personal information in systems that look for fraud by studying patterns in the data. We may find that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. Either of these could indicate a possible risk of fraud or money-laundering.

How this can affect you

If we or an FPA decide there is a risk of fraud, we may stop activity on the accounts or block access to them. FPAs will also keep a record of the risk that you or your business may pose.

This may result in other organisations refusing to provide you with products or services, or to employ you.

Data transfers out of the EEA

FPAs may send personal information to countries outside the European Economic Area (‘EEA’). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.

Sending data outside of the EEA

We will only send your data outside of the European Economic Area (‘EEA’) to:

· Follow your instructions.

· Comply with a legal duty.

· Work with our agents and advisers who we use to help run your accounts and services.

If we do transfer information to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:

· Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.

· Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website,

· Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.

If you choose not to give personal information

We may need to collect personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your portfolio. It could mean that we cancel a product or service you have with us.

Any data collection that is optional would be made clear at the point of collection.

Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.

The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We study this 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, services and offers may be relevant for you.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

You can ask us to stop sending you marketing messages by contacting us at any time.

Whatever you choose, you'll still receive statements, and other important information such as changes to your existing products and services.

We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.

If you change your mind you can update your choices at any time by contacting us.

How long we keep your personal information

We will keep your personal information for as long as you are a customer of Wellington Wealth (Glasgow) Limited

After you stop being a customer, we may keep your data for up to 10 years for one of these reasons:

· To respond to any questions or complaints.

· To show that we treated you fairly.

· To maintain records according to rules that apply to us.

We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.

How do I get a copy of my personal data

You can access your personal information we hold by filling in this form or by writing to us at this address:

Wellington Wealth (Glasgow) Limited

Personal Information Request

5th Floor Gordon Chambers

90 Mitchell Street

Glasgow

G1 3NQ

Letting us know if your information is incorrect

You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this or update the information by logging into our client portal.

If you do, we will take reasonable steps to check its accuracy and correct it.

What if you want us to stop using your personal information?

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal information if:

· It is not accurate.

· It has been used unlawfully but you don’t want us to delete it.

· It not relevant any more, but you want us to keep it for use in legal claims.

· You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us using this form or give us a call on 0141 221 3222.

How to withdraw your consent

You can withdraw your consent at any time. Please use this form if you want to do so or call us on 0141 221 3222.

How to complain about our use of your data

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

Please let us know if you are unhappy with how we have used your personal information. You can contact us using our secure online contact form.

You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.

Future formats for sharing data

The Data Privacy laws will change on 25 May 2018. From that date you will have the right to get your personal information from us in a format that can be easily re-used. You can also ask us to pass on your personal information in this format to other organisations.

Cookies

This website is owned by Wellington Wealth (Glasgow) Limited. Here is our cookie policy for this site and the type of cookies we use on it.

What are cookies?

At Wellington Wealth (Glasgow) Limited, we prefer eating or making cookies as part of our 'Office Bake Off' .

However in reference to the web, cookies are small files that websites place on the device you're using to browse the site. Cookies are commonly used to record some aspect of your visit to a site, such as choices you've made or preferences you've set during your visit.

How and why we use cookies

We use cookies to give you the best experience when you visit our website. By using cookies, we can make it easier for you to do many things, such as managing your login details. Cookies can also allow us to tailor the content of our website so we can show you service we think you might be interested in.

Keeping you personal information safe

Our cookies do not store personal information such as your name, address, phone number or email in a format that can be read by others. The cookies we use cannot read or search your computer, smartphone or web-enabled device to obtain information about you or your family, or read any material kept on your hard drive.We do use a small number of cookies that store encrypted versions of information where you have asked us to, such as the ‘Remember me’ function that allows us to remember your Account username for subsequent visits. However, this is encrypted so that only we can read this information. The website that places a cookie owns that cookie. This means only that website and other sites that it has agreed to share information with can read the information stored using a cookie.

Links to sites by other providers

If you follow a link from our website to another website, please be aware that the owner of the other website will have their own privacy and cookie policies for their site. We recommend you read their policies as we are not responsible or liable for what happens on their site.

How to manage and switch off cookies

Your web browser provides settings that allow you to manage or switch off cookies, remember that you may not be able to use all of the services on our websites.

You can find out more about managing and switching off cookies at the independent website allaboutcookies.org

Strictly necessary cookies

These cookies are essential for our online services and tools to work. They collect and record information that we need to make our site work.

Common uses for this type of cookie include;

- Allowing user to log in or access private areas of our site.

These cookies only last for a single browsing session when you leave our site they are removed.

Performance cookies

These cookies help us to monitor and improve how our website works.

Common uses;

- collecting information about which pages visitors go to most often

- noting if visitors get any error messages from web pages

- understanding which links visitors like to follow and which they choose not to.

The information collected using these cookies is anonymous and cannot be used to identify and individual visitor

Functionality cookies

These allow us to provide you with enhanced features that need to remember your preferences and choices, such as your username, language or region. They also let us monitor how our website is performaing so we can keep improving it.

Common uses;

- providing you with local information

- remembering how you like to use our site

- remember ing topics you interested in.

the information stored in these cookies is encrypted so we can only read it.

Google Analytics Addendum

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files saved on your computer, to help the website analyze how you use the site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. If this website anonymizes IP addresses, your IP address will be truncated by Google within a EU member state or other EEA state before being transmitted to the US. Only in exceptional situations will your full IP address be transmitted to Google servers in the United States and truncated there. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You can also prevent Google from collecting information (including your IP address) via cookies and processing this information by downloading this browser plugin and installing it: http://tools.google.com/dlpage/gaoptout

You can prevent data collection via Google Analytics by clicking here. An "Opt-out Cookie" shall then be applied to your website which shall prevent any future collection of your data when visiting this website.

Further information concerning the terms and conditions of use and data privacy can be found at the Google Analytics Terms of Service or at the Google Analytics Privacy Overview. Please note that on this website, Google Analytics is supplemented by "gat._anonymizeIp();" to ensure anonymized collection of IP addresses (IP masking).

reCAPTCHA

We use the reCAPTCHA service provided by Google Inc. (Google) to protect your submissions via internet submission forms on this site. This plugin checks if you are a person in order to prevent certain website functions from being (ab)used by spam bots (particularly comments). This plugin query includes the sending of the IP address and possibly other data required by Google for the Google reCAPTCHA service. For this purpose your input will be communicated to and used by Google. However, your IP address is previously truncated by Google within member states of the European Union or in other states which are party to the agreement on the European Economic Area and is, as such, anonymized. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address provided by reCaptcha from your browser shall not be merged with any other data from Google.
This data collection is subject to the data protection regulations of Google (Google Inc.). For more information about Google's privacy policy, please visit: https://www.google.com/intl/en/policies/privacy/
By using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out above.