Privacy Notice

We may collect your personal information directly from you, or from a variety of sources, including:

• application forms for products or services
• electronic ID verification services – we use this data to verify and authenticate client identities for anti-money laundering and fraud detection / prevention
• credit reference agencies
• recorded video or telephone conversations with your IFA or us
• emails or letters you send to us
• meetings with your financial or mortgage adviser
• registering for one of our events, either in person or online webinars
• participating in research surveys or feedback forms to help us understand you better and improve our products and services
• our online services such as websites, newsletters, social media and mobile device applications (‘Apps’)
• from other organisations such as banking services, investment / pension / insurance / mortgage providers, where you have provided authority for them to share information relating to your existing plans.
• from your professional advisers such as accountants, where you have provided authority for them to share information.

If you use a financial or mortgage adviser from our group of companies, the information we collect and use will most likely have been provided by them on your behalf. We may also collect personal information on you from places such as business directories and other commercially or publicly available sources e.g. to verify your identity, to comply with our anti-money laundering and financial crime obligations, check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.

We take your privacy seriously and we will only ever collect and use information that is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:

• you have given us your permission [consent] to send you information about products and services offered by Finli, its subsidiaries and / or selected third parties we have chosen to work with which we believe may be of interest and benefit to you, or;
• it is necessary to provide the products or services you have requested e.g. if you wish to take out any of the pensions, investments, mortgages, loans or insurances available through the Finli Group. Typically to facilitate this we will require personal information including your name, address, date of birth, and financial details, or;
• it is necessary for us to meet our legal or regulatory obligations e.g. to ensure the suitability of our recommendations to your needs, to send you Annual Review Letters or Statements, tell you about changes to Terms and Conditions or for the detection and prevention of fraud and other types of financial crime, or;
• it is in the legitimate interests of Finli and / or its subsidiaries e.g. so we can deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from your product or investment as well as to better understand you and your needs so we can send you more relevant communications about the products you have with us and to develop new products and services;
• it is in the legitimate interests of a third party e.g. sharing information with the providers of products or services you have chosen through us.

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services. We will only use your personal data when the law allows us to.  Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you.
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• where we need to comply with a legal or regulatory obligation such as anti-money laundering or combatting financial crime.

In order to process applications you choose to make through one of our subsidiaries, we may supply your personal information to credit reference agencies (CRAs)who will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

For more information about CRAs, please visit www.experian.co.uk/crain/ or https://www.equifax.co.uk/ein.

We rely on consent as a legal basis for processing your personal data only in relation to sending third party or direct marketing communications to you.  You have the right to withdraw consent to marketing at any time by contacting us.  More information on legal bases is available visiting the ICO website at www.ico.org.

We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect and use from others – about you. These automated decisions can affect the products, services or features we offer you now or in the future. We use automated decisions in the following ways:

• to tailor products and services e.g. placing you in groups with similar customers to make decisions about the products and services we may offer you to help meet your needs
• to design and enhance our online services to help meet your requirements for ongoing guidance and support.

For further information on your rights relating to automated decisions, please see the section on YOUR INDIVIDUAL RIGHTS.

We may share your information with third parties for the reasons outlined in ‘What we collect and use your information for.’ These third parties include:

• companies within the Finli Group
• your financial or mortgage adviser
• companies we have chosen to support us in the delivery of the products and services we offer to you and other customers e.g. research, consultancy or technology companies; or companies who can help us in our contact with you
• our Regulators and Supervisory Authority e.g. the Financial Conduct Authority (FCA), the Information Commissioner’s Office for the UK (the ICO)
• law enforcement, credit and identity check agencies for the detection and prevention of crime
• HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance
• In some cases, we may choose to buy or sell assets. In these business transfers, client information is typically one of the business assets that are transferred. Moreover, if all or substantially all of our business assets were acquired, or in the unlikely event that we go out of business or enter into bankruptcy, client information would be one of the assets that is transferred or acquired by a third party. These transfers are a legitimate interest.

Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

We will keep your personal information where it is necessary to provide you with our products or services while you are a customer with us and where it is reasonably required for the purposes set out in this Privacy Notice.  We are also subject to regulatory requirements to retain your data for specified minimum periods.  These are, generally:

• Five years for investment business
• Three years for mortgage and insurance business
• Indefinitely for pension transfers and opt outs

We may also keep your information after this period but only where it is required to meet our legal, regulatory, tax or accounting obligations.  For example, we are required to retain accurate records of your dealings with us to respond to any complaints, challenges, litigation or queries that you or others may raise in the future. Therefore, length of time we keep your information for these purposes will vary depending on the obligations we need to meet and can be viewed in our data retention policy.

You have several rights in relation to how Finli processes your information. They are:

The right to be informed You have a right to receive clear and easy to understand information on what personal information we have, why we have it and who we share it with. This can be found in our Privacy Notices.

The right of access You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a Data Subject Access Request (DSAR) by contacting us using the methods provided above in the ‘How to contact us’ section.

The right to request that your personal information be rectified If you believe the personal information we hold about you is inaccurate or incomplete, you can request that it is corrected.

The right to request erasure You can ask for your information to be deleted or removed if there is not a compelling reason for Finli to continue to have it.

The right to restrict processing You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.

The right to data portability You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your pension to another pension provider.

The right to object You can object to Finli processing your personal information where: it is based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.

Rights related to automatic decision-making including profiling You have the right to ask Finli to:

• give you information about its processing of your personal information
• request human intervention or challenge a decision where processing is done solely by automated processes
• carry out regular checks to make sure that our automated decision-making and profiling processes are working as they should.

Marketing

We would like to send you information about our products and services and those of other companies in the Finli Groupwhich may be of interest to you.  If you have agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the Group.  If you no longer wish to be contacted for marketing purposes, please use the contact details at the top of this notice.