Privacy Policy
Privacy Policy
We take your privacy very seriously and ask that you read this notice carefully, as it contains important information about who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data, and how to contact us and supervisory authorities if you have a complaint.
Kingsmarque Wealth Management Ltd (‘we’, ‘us’ or ‘our’) collects, uses and is responsible for personal data about you. We are required to comply with applicable data protection legislation and are the data controller responsible for that personal data.
We provide financial planning, financial advice and intermediary product arrangement services to individuals and businesses.
Personal Data We Collect From You
In the course of providing our service to you, we may collect the following personal data when you provide it to us:
Contact Information
This includes any information that can be used to contact a person, such as title, forename, surname, personal telephone number and email address. This may also include work contact information such as business name, work telephone number and email address.
Financial and Special Category Information
In order to provide these services, we will capture and store a number of details you provide regarding your personal circumstances. This may include financial information and special category data, such as health information. Where we process special category data, we will ensure that we have a lawful basis under Article 6 of the UK GDPR and meet an applicable condition under Article 9 of the UK GDPR.
In order to provide our services, we may need to share such information with a number of third-party organisations, particularly for the purposes of obtaining quotations for financial products and services, performing identity verification and submitting applications on your behalf.
How We Use Your Personal Data
The table below sets out how we use your personal data, the lawful bases upon which we collect and use your personal data, and who we routinely share your personal data with:
| Reason for Data Processing | Lawful Basis for Data Processing | Who We May Share Your Personal Data With |
|---|---|---|
| To provide you with financial planning, financial advice and any intermediary services. | Performance of a contract. | Product providers, investment platforms, insurers, lenders, pension providers, identity verification providers, professional advisers and other service providers involved in providing or arranging services on your behalf. |
| To provide you with details of products and services that we or third parties offer and that may be of interest to you in accordance with your preferences. | Consent. | Marketing service providers and relevant third-party service providers, where applicable and in accordance with your preferences. |
| To retain records of any financial planning, financial advice, product arrangement or other services provided to you by us to meet regulatory requirements. | Compliance with a legal obligation. | Regulators, compliance consultants, auditors, professional advisers and other parties where disclosure is required by law or regulation. |
| To retain records of any financial planning, financial advice, product arrangement or other services provided to you by us to defend potential complaints or legal claims. | Legitimate interests. | Professional advisers, insurers, complaints handling bodies, dispute resolution services, courts or tribunals, where applicable. |
In the course of activities relating to the prevention, detection and investigation of financial crime, we may process personal data relating to criminal convictions and offences (‘criminal offence data’). Where we do so, we will ensure that we have a lawful basis under Article 6 of the UK GDPR and meet the additional requirements of Article 10 of the UK GDPR and the Data Protection Act 2018. We process this information to comply with regulatory requirements relating to unlawful acts and dishonesty.
Marketing
We may use personal data that we hold about you to help us identify, tailor and provide you with details of products and services from us or third parties that may be of interest to you in accordance with your preferences.
Where you have opted to receive marketing communications, you can change your marketing preferences at any time by contacting us directly. You can also opt out of marketing communications by clicking the ‘Unsubscribe’ link at the bottom of any marketing email.
When Information Must Be Provided By You
We will tell you when providing personal data is optional. Where we need personal data to enter into or perform a contract with you, or to meet a legal or regulatory obligation, we will tell you what information is required. If you do not provide it, we may be unable to provide some or all of our services.
How Long Your Personal Data Will Be Kept
We will retain personal information only for as long as necessary for the purposes for which it was collected, including to satisfy applicable legal, regulatory, accounting and reporting requirements, and to establish or defend legal claims.
When deciding how long to retain personal information, we consider its nature, amount and sensitivity; the potential risk of harm from unauthorised use or disclosure; the purposes for which we process it and whether those purposes can be achieved by other means; and applicable legal and regulatory requirements.
When we no longer need to retain personal information, we will either delete it or anonymise it. If this is not possible, we will securely store it and isolate it from any further processing until deletion becomes possible.
International Data Transfers
Where we initiate a restricted transfer of personal data to a separate organisation outside the UK, we will ensure that the transfer is covered by one of the following:
- UK adequacy regulations;
- Appropriate safeguards; or
- An exception (called a ‘derogation’ in the legislation).
Your Rights
You have legal rights under data protection legislation in relation to your personal data as follows:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to Contact Us” heading below;
- In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information or request the transfer of your personal information to another organisation where applicable. Again, you can exercise these rights by contacting us using the contact details provided under the “How to Contact Us” heading below;
- You have the right to opt out of marketing communications that we send you at any time. You can exercise this right by clicking on the “Unsubscribe” or “Opt out” link in the marketing emails we send you. To opt out of other forms of marketing, such as postal marketing or telemarketing, please contact us using the contact details provided under the “How to Contact Us” heading below;
- Similarly, if we have collected and processed your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent;
- You have the right to complain to the Information Commissioner’s Office about our collection and use of your personal information. For more information, please see below under the heading “Our Supervisory Authority”.
Your right to object to direct marketing
You have an absolute right to object at any time to the use of your personal information for direct marketing.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Keeping Your Personal Data Secure
We have appropriate security measures in place to prevent personal data from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Anyone processing your information will do so only in an authorised manner and will be subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected personal data breach. We will notify you and the applicable regulator of a personal data breach where we are legally required to do so.
Our Supervisory Authority
If you are not happy with the way we collect and use your personal information, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). The ICO has enforcement powers and can investigate compliance with data protection legislation.
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113. Fax: 01625 524510. Website: www.ico.org.uk
Please contact us first so that we can try to resolve your concerns before you refer the matter to the ICO.
How to Contact Us
If you are not satisfied with the level of information provided, or you would like to exercise any of the above rights or make a complaint, please email:
The Data Protection Officer at dataprotection@kingsmarquewm.com, or write to:
The Data Protection Officer
Kingsmarque Wealth Management Ltd
71-75 Shelton Street
Covent Garden
London WC2H 9JQ
Please provide enough information to identify yourself, such as your name, telephone number and email address.
We may ask you to provide proof of your identity and address where this is necessary to verify your identity. Please also explain the information to which your request relates.
