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GilesSmith is the Operator and Copyright Holder respectively of this website (“the Site”). GilesSmith respects your privacy and will not sell or make available in any way the personal information we collect from you (“Data”) except where we have previously obtained your consent. The nature of the Services provided via the Site means that we might obtain certain information about you. This statement sets out the principles governing our use of your Data (“Use”). By Registering to use the Services and by using the Site generally, you agree to this Use. Defined terms have the same meanings as in the terms and conditions set out above.
When you Register and use the Site, we will ask you to provide certain Data, such as your contact details and demographic information. We will store this Data and use it to contact you, provide you with details of Services and otherwise for the normal use and improvement of the Site, unless you have asked us not to do so by clicking on the appropriate tickbox at Registration or by modifying your profile anytime thereafter.
We may also use the Data you provide us in response to surveys or provided during Registration to aggregate user profiles and to make you aware of relevant events and content by post, phone, email/SMS. For the avoidance of doubt, we do not pass Data to any third parties except in the following circumstances:
To enable us to monitor and improve the Site, we may gather certain information about you when you use the Site. This includes details of your operating system, browser version, domain name and IP address, and the details of the website you referred from.
We maintain a record of all the articles that have been sent via the Email a Friend facility on the Site. We will keep a record of the email addresses that articles are sent to and from. We keep a record of the content and comments sent by Registered Users and Visitors using the Email a Friend facility for research purposes and from time to time we may publish on our Site some of the comments made by Registered Users and Visitors in their emails. These comments will be ANONYMISED and will not be associated to any individual sender or recipient. You accept that by using the Email a Friend facility that your comments may be published, anonymously, on our Site.
We are not responsible for the data policies, procedures or content of any other website that are linked to our Site.
We endeavour to take all reasonable steps to protect your Data, including the use of encryption technology, but cannot guarantee the security of any Data you disclose online. You accept the inherent security implications of dealing on-line over the Internet and will not hold us responsible for any breach of security unless we have been negligent or in wilful default.
We may supplement the information that you provide us with information we receive from third parties. You have the right to receive information about the personal information we hold on you. You can obtain a copy of the information we hold about you by sending an email to [email protected] or contacting us on 01243 271291. If you are concerned that any of the information we hold on you is incorrect, please contact us at 01243 271291.
We have certain responsibilities under legislation to verify the identity of Registered Users and users and may need to make certain enquiries and obtain certain information from you for that purpose. By using the Site you confirm that all information you supply will be accurate and that we may pass on such information, as we consider necessary, to comply with any reporting requirements.
To ensure that our records are up-to-date, we may contact you from time to time to check that the information you have provided is still accurate. If, at any stage, any of your details change and you would like us to reflect that change, please email the details of any changes [email protected].
The information you have provided is subject to the General Data Protection Regulation (Regulation (EU) 2016/679). (GDPR)
Your data will be used for the sole purpose of providing financial advice, administration and management.
“Processing” includes obtaining, recording or holding information or data, transferring it to other companies associated with us, such as product providers, the FCA or any other statutory, governmental or regulatory body for legitimate purposes including, where relevant, to solicitors and/or other debt collection agencies for debt collection purposes and carrying out operations on the information or data.
In order to provide services to you we may be required to pass your personal information to parties located outside of the European Economic Area (EEA) in countries that do not have Data Protection Laws equivalent to those in the UK. Where this is the case we will take reasonable steps to ensure the privacy of your information.
The information provided may also contain sensitive personal data for the purposes of the Act, including information that relates to your physical or mental health or condition; the committing or alleged committing of any offence by you; any proceedings for an offence committed or alleged to have been committed by you, including the outcome or sentence in such proceedings.
We are required by the anti-money laundering regulations to verify the identity of our clients, to obtain information as to the purpose and nature of the business which we conduct on their behalf, and to ensure that the information we hold is up-to-date. For this purpose we may use electronic identity verification systems and we may conduct these checks from time to time throughout our relationship, not just at the beginning.
When using electronic identity verification systems, we utilise the services of a Credit Reference Agency. For further information about Transunion and the information it holds, please follow the below link:
If at any time, should you wish to withdraw consent for us or any company associated with us to processing your personal data or sensitive personal data, please contact The Data Protection Officer on 01243 271291 or [email protected]
or in writing at:
GilesSmith Wealth Management LLP
27 East Street
You may also wish alter your marketing preferences by accessing your own personal client site. Log in details, to access your client site, will be provided once your registration is complete.
You may be assured that we and any company associated with us will treat all personal data and sensitive personal data as confidential and will not process it other than for a legitimate purpose associated with the service we will provide you. Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary.
If we provide you with financial advice, your data will be kept in accordance with FCA regulatory expectations, which in some cases mean the duration could be indefinite.
Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the data.
Subject to certain exceptions, you are entitled to have access to your personal and sensitive personal data that is held by us.
You will not be charged for us supplying you with such data, however we do reserve the right to apply a ‘reasonable fee’ where requests are deemed excessive.
We will respond to your request as soon as possible and within the maximum time frame of one month.
Your data will be lawfully and fairly processed in a transparent manner.
Your data is collected on the grounds of explicit and legitimate purposes only.
We will only ask for your data when necessary, explain if data will be shared and how long it will be kept.
Your data will be accurate, kept up to date and erased, without delay, should your data no longer be required for the purposes to be processed.
Your data will only be retained for as long as is necessary.
Your data will be secure.
Rights of the client
The points below clearly set out the rights each client is entitled to. Please ask us for an explanation of each, should you wish to have more information.
Right to complain
In rare occasions where you believe your data has been wrongfully processed, stored or handled, you have the right to raise a concern with the Information Commissioner’s Office (ICO).
Details on how to do this can be found here:
Communication and Marketing Preferences
Occasionally, we may send you marketing/promotional communications via email, telephone, SMS or the post. Recipients will be carefully selected, and information will only be sent where we feel it to be appropriate.