This notice sets out how we collect and use your personal data in compliance with the Data Protection Act 2018.
You may contact us with any queries or complaints regarding our use of personal data by emailing us at firstname.lastname@example.org or calling us at +44 (0)20 3002 0339.
The personal data we collect and our legal basis for processing.
When you sign up for our services we will obtain personal data from you, including:
- basic information including your name, address, age, sex, occupation and marital status;
- information on your investment experience, income level and portfolio size, and attitude to risk;
- contact details including email address and telephone number;
- copies of proof of identity, (such as a scan of your passport or driver’s license) plus any supporting documents to provide proof or clarification of any information relating to you or your account.
We use this data in order to enter into a services contract with you, to assess your suitability and risk appetite (if you are signing up for an advisory or asset management service), and to comply with our legal and regulatory obligations, such as the FCA’s Handbook and the Money Laundering and terrorist financing Regulations 2019.
All the personal data we obtain will be collected and processed in accordance with one of the below lawful bases for processing:
- the performance of a contract (your basic information, contact details, and information on investment experience, portfolio size, and objectives)
- compliance with our legal obligations (identity and address proofs as well as any other information obtained for anti-money laundering know your customer (AML/KYC) purposes or other legal obligations we are subject to);
- our legitimate interests (see below);
- your consent (in certain circumstances, please see below).
Our legitimate interests
In some circumstances we may rely on our legitimate interests for processing your personal data and sharing this with third parties (for more on who we share data with on this basis, see below).
Our “legitimate interests” in this context can be defined as a general commercial interest in providing a broad range of services to our clients and growing our core client base by way of marketing activity.
Who will use the personal data we collect
All electronic copies of the personal data we collect will be held securely, in encrypted format, on secure servers. All physical copies will be kept in locked filing cabinets within our principle place of business.
We may share your data with our legal advisers in circumstances where there is contemplation of any relevant litigation or legal action.
In accordance with our legitimate interests, we may share your data with other members of our group, including:
Neovision Global Capital Ltd and Neovision Asset Management Ltd.
We will do so in order to offer you the broadest range of services possible and put you in touch with other members of our group if we think that you may require the services that they offer. You can opt out of this sharing at any time by contacting us using the contact details above.
If it is necessary in the performance of our services to you we will pass your data to other parties for example investment companies, pension administrators and insurers.
Transfers outside the UK and safeguards
The personal data we hold will not be transferred outside the UK for any reason. If this changes, we will reflect this in an updated privacy notice.
You may explicitly consent to us passing on certain details to third parties for general marketing purposes. You may be given the option to provide this consent during the sign-up process with Neovision Wealth Management. We will never assume that you have given us consent unless you explicitly do so, and you may withdraw your consent at any time by contacting us.
You have various rights in relation to the personal data we collect, including the “right to portability” and the “right to erasure” of your data. Your rights change depending on the legal basis upon which we are processing your information. If you wish to assert any of these rights, please contact us.
Please note that you cannot request the erasure of the AML/KYC information we hold as we must retain this information under the Money Laundering and Terrorist Financing Regulations 2019.
How long we will keep your data for
We will only keep your personal data for as long as is necessary. This means that we will retain your personal data for as long as we have an active contract or business relationship with you, and after this, we will only keep your data for as long as is necessary to comply with the FCA’s record keeping rules and retention periods mandated by the Money Laundering and Terrorist Financing Regulations 2019, as well as any other relevant legislation.
What happens if you don’t provide us with the personal data we need.
As outlined above, some of the personal data you provide to us will be used in order to enter into a contract with you and to comply with our legal obligations.
If you refuse to provide us with this data or make a request for erasure, it is likely that we will be unable to continue with our client onboarding process, or would have to terminate our existing contractual relationship.
If you refuse to provide or update us with the data we need to comply with our legal obligations, such as AML/KYC information, we will be unable to open an account or continue an existing business relationship with you.
If you feel that we have not been complying with our obligations under data protection law or you wish to assert one of your rights, please contact us without delay using the contact details provided above.
If you are dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the Information Commissioner’s Office (ICO).