PRIVACY STATEMENT

Privacy Notice for
Independence Assured Limited
October 2024

If you would like this document in larger print or in another format, please contact us.

This privacy notice explains how we use any personal information we collect.

What information do we collect about you?

We collect information about you when you engage us for financial planning, financial advice,
mortgage advice or investment management services. This information will relate to your personal  and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.

We may also collect information when you voluntarily complete client surveys or provide feedback  to us.

It should also be noted that our premises are protected by CCTV cameras and therefore if you visit your image will be recorded and stored by our provider Veritech. There is a visible sign on the side gate that allows access to the office area informing that CCTV is in operation. If you do not wish your image to be stored please advise a member of staff accordingly.

Information about connected individuals

We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.

Why do we need to collect and use your personal data?

We must have a lawful basis to process your personal data. Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

We have a contractual obligation

This is the primary legal basis that we intend to use for processing your data. The personal
information that we collect about you is essential for us to be able to effectively carry out the
services that we have agreed to deliver to you.

We have a legal obligation

Sometimes, collecting personal data is needed to meet our legal and regulatory obligations. For
example, UK anti money laundering legislation may require us to collect personal information to
verify your identity.

We will obtain your consent

Special category data, such as that relating to health matters, is often required to provide our
services. When this is required, we will obtain your explicit consent to collect and process this
information.

From time to time, we may wish to contact you to offer additional products or services which may
be of interest to you. To do this, we will obtain your consent.

You may withdraw your consent at any time by notifying us at our main business address.

We have a legitimate interest

We rely on legitimate interest to retain relevant data for the purposes of assessing the
appropriateness of our services, defending future complaints, and meeting our Professional
Indemnity Insurer’s expectations.

How will we use the information about you?

We collect information about you in order to provide you with the services for which you engage us.

Who might we share your information with?

If you agree, we may write to you or email you about other products or services that we think may
be of interest to you.

We will not share your information for marketing purposes with other companies.

In order to deliver our services to you effectively we may send your details to third parties such as
those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.

Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.

Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit via password protection.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime, we may send your details to third party agencies for identity verification purposes.

How long do we keep hold of your information?

During the course of our relationship with you, we will retain personal data which is necessary to
provide services to you. We will take all reasonable steps to keep your personal data up to date
throughout our relationship.

We are also subject to regulatory requirements to retain your data for specified minimum periods.

These are, generally:

• 5 years for investment business
• 3 years for mortgage business
• Indefinitely for pension transfers and opt-outs
• 3 years for insurance business

These are minimum periods, during which we have a legal obligation to retain your records.

We reserve the right to retain data for longer where we believe it is in our legitimate interests to do so. In any case, we will not keep your personal data for longer than 10 years after our relationship with you has ended.

You have the right to request deletion of your personal data. We will comply with this request,
subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information please email or write to us using the contact details noted below.

When your personal data is processed by automated means, you have the right to ask us to move
your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please
ask us to correct or remove any information that you think is incorrect.

Marketing

We would like to send you information about our products and services which 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. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.

What can you do if you are unhappy with how your personal data is processed?

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Changes to our privacy policy

We keep our privacy policy under regular review and we will inform you of any changes when they occur. This privacy policy was last updated on 17th October 2024.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about
you by telephone on: 01202 311331.

Or write to us at:

Independence Assured Limited
55 Braidley Road
Bournemouth
Dorset
BH2 6JY

Please note that we are not responsible for the accuracy or content of any sites linked from our own site, nor for the way in which those linked sites might handle any information that you choose to provide them with. We cannot be responsible or liable for any direct or indirect loss however caused by your use of these linked sites.

These Terms shall be governed by and construed in accordance with English law and the English courts shall have jurisdiction over any disputes between us.

The majority of this site may be accessed without your having to provide any personal or identification details whatsoever. However, in order to advise you properly, we must obtain certain information from you about your financial and personal circumstances, to assess the suitability for particular products and services for your needs. If you wish us to provide advice you can telephone us to arrange a meeting, or you will need to register through the secure area of our site, or complete an enquiry form, to provide us with basic personal and contact details, and in some cases further personal data such as health and medical conditions.

By providing us with your personal data:

1. You agree that the information we hold about you can be held on computer (whether local or web-based) and/or paper files.

2. Where stored on our secure web server, we undertake to password protect your data giving direct access only to yourself, ourselves, and third parties who may need to maintain the database e.g. PracticeWEB Ltd who manage our website.

3. You may at any time, either online or by phone, request that your username and/or password to access your personal information be changed to one of your choice.

4. You may access the information you have provided to us 24/7, for the purposes of viewing/ amending or updating it. Any changes you make will be stored on our secure database, and we will be notified that changes have been made.

5. You can read our cookie policy here.

6. We aim to take all reasonable and appropriate steps to protect the personal information that you provide to us from unauthorised access or disclosure.

7. You agree that any information which you give us, including sensitive personal data as defined by the Data Protection Act 2018 such as health and medical records, may be disclosed to third parties (e.g. credit reference agencies and medical practitioners, where relevant, product providers and anyone whom we may use to process your application on our behalf) for the purpose of processing your application and for the on-going administration of your investment or policy but for no other purpose. Your information may also be accessed by PracticeWEB Ltd for the purpose of web site maintenance and administration, and the Financial Conduct Authority for investigative work, and fraud prevention agencies if requested to do so in order to meet our responsibilities under the Financial Services and Markets Act 2000 and general United Kingdom law.

8. You agree that we may use the information that we hold about you to contact you from time to time by post, fax, email or telephone to bring to your attention additional products or services, which may be of benefit to you or comments and news features which may be of interest to you.

9. In accordance with the Privacy and Electronic Communications Regulations 2003 we agree that any consent given by you under paragraphs 7 and 8 above may be withdrawn by you at any time by contacting us.